A. Firm Information
TCN Private Wealth Management LLC (“TCN Private Wealth Management” or the “Advisor”) is a registered
investment advisor with the U.S. Securities and Exchange Commission. The Advisor is organized as a Limited
Liability Company (LLC) under the laws of the State of New York. TCN Private Wealth Management was founded
in August 2020 and is owned and operated by Timothy C. Neale (Principal and Chief Compliance Officer). This
Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by TCN Private Wealth Management.
B. Advisory Services Offered
TCN Private Wealth Management offers investment advisory services to high net worth individuals, trusts,
estates and businesses (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the 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. TCN Private Wealth Management'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.
Investment Management Services
TCN Private Wealth Management provides customized investment advisory solutions for its Clients. This is
achieved through continuous personal Client contact and interaction while providing discretionary investment
management and related advisory services. TCN Private Wealth Management works closely with each Client to
identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a
portfolio strategy. TCN Private Wealth Management will then construct an investment portfolio, consisting of low-
cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals.
The Advisor may also utilize individual stocks, bonds, options contracts, and alternative investments to meet the
needs of its Clients. The Advisor may retain certain types of investments based on a Client’s legacy investments
based on portfolio fit and/or tax considerations.
TCN Private Wealth Management ’s investment strategies are primarily long-term focused, but the Advisor may
buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or
due to market conditions. TCN Private Wealth Management will construct, implement and monitor the portfolio to
ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will
have the opportunity to place reasonable restrictions on the types of investments to be held in their respective
portfolio, subject to acceptance by the Advisor.
TCN Private Wealth Management evaluates and selects investments for inclusion in Client portfolios only after
applying its internal due diligence process. TCN Private Wealth Management may recommend, on occasion,
redistributing investment allocations to diversify the portfolio. TCN Private Wealth Management may recommend
specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash
positions as a possible hedge against market movement. TCN Private Wealth Management may recommend
selling positions for reasons that include, but are not limited to, harvesting 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.
At no time will TCN Private Wealth Management accept or maintain custody of a Client’s funds or securities,
except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed
within the
designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 –
Brokerage Practices.
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Use of Independent Managers
TCN Private Wealth Management will recommend that Clients utilize one or more unaffiliated investment
managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s
investment portfolio, based on the Client’s needs and objectives. In such instances, the Client will be required to
authorize and enter into an investment management agreement with an Independent Manager that defines the
terms in which the Independent Manager will provide its services. The Advisor will perform initial and ongoing
oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients
investment objectives and overall best interests. The Advisor will also assist the Client in the development of the
initial policy recommendations and managing the ongoing Client relationship. The Client, prior to entering into an
agreement with an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A -
Disclosure Brochure (or a brochure that makes the appropriate disclosures).
Non-Purpose Loans and Lines of Credit
The Advisor may introduce certain Clients to a non-purpose line of credit made available through 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 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 and lines of credit, please see Item 8 - Methods of
Analysis, Investment Strategies and Risk of Loss.
C. Client Account Management
Prior to engaging TCN Private Wealth Management to provide investment advisory services, each Client is
required to enter into an agreement with the Advisor that defines the terms, conditions, authority and
responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – TCN Private Wealth Management, in connection with the Client,
will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – TCN Private Wealth Management will develop a strategic asset allocation that is
targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for
each Client.
• Portfolio Construction – TCN Private Wealth Management will develop a portfolio for the Client that is
intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – TCN Private Wealth Management will provide investment
management and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
TCN Private Wealth Management includes securities transaction fees together with its investment advisory fees.
Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes
its investment management services for its Clients. The Advisor sponsors the TCN Private Wealth Management
Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. 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 its own transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure,
which is included as a supplement to this Disclosure Brochure.
E. Assets Under Management
Assets under management are as follows:
Discretionary: $ 94,013,459.69
Non-Discretionary $ 9,187,318.88
Total: $103,200,778.57
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