Our firm is dedicated to providing our clients with a wide array of investment advisory services. We
have been in the investment industry since 1998; in 2021 our firm created a limited liability company
formed under the laws of the State of Vermont and has been in business as an investment adviser
since 2021. Our firm is wholly owned by Richards, Inc. Our firm is managed by Benjamin Taggard,
an investment advisor representative.
As a fiduciary, it is our duty to always act in our client’s best interest. This is accomplished in part by
knowing our client. Our firm has established a service-oriented advisory practice with open lines of
communication for many different types of clients to help meet their financial goals while remaining
sensitive to risk tolerance and time horizons. Working with clients to understand their investment
objectives, while educating them about our process, facilitates the kind of working relationship we
believe will be most valuable to our clients. The purpose of this Brochure is to disclose any conflicts
of interest associated with the investment transactions, compensation and any other matters related
to investment decisions made by our firm or its representatives.
Types of Advisory Services Offered
Wrap Comprehensive Portfolio Management:
Please refer to the Wrap Fee Program Brochure for more information regarding our Wrap
Comprehensive Portfolio Management service offering.
529 Account Management:
As part of this service, we manage section 529 accounts with portfolios consisting of mutual funds
available through American Funds (“AF”), the family of funds available from Capital Group. The purpose
of this service is to assist clients in the investment of funds for future educational costs. We will not
evaluate any type of security other than mutual funds offered by AF. Portfolios will be designed to meet
a particular investment goal based on the expected educational needs and time horizon related to the
managed account.
Asset Management:
As part of our Asset Management service, a portfolio is created, consisting of individual stocks, bonds,
exchange traded funds (“ETFs”), certificates of deposit, variable annuities, mutual funds and other public
and private securities or investments. The client’s individual investment strategy is tailored to their
specific needs and may include some or all of the previously mentioned securities. Portfolios will be
designed to meet a particular investment goal, determined to be suitable to the client’s circumstances.
Once the appropriate portfolio has been determined, portfolios are regularly monitored, and if
necessary, rebalanced based upon the client’s individual needs, stated goals and objectives.
ADV Part 2A – Firm Brochure Page 5 TRG Investment Advisors
Retirement Plan Consulting:
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising may include:
• Assist in the structure and responsibilities of the plan’s Retirement Plan Committee;
• Provide fiduciary education and best practices to Retirement Plan Committees;
• Provide quarterly monitoring and reporting on the plan’s investment lineup;
• Evaluate vendor service model and benchmark fees and expenses;
• Assist in the development and maintenance of the plan’s fiduciary audit file;
• Conduct on-site and/or virtual group and individual employee education sessions;
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
funds and publicly traded REITS) Non-publicly traded REITS, other non-publicly traded securities or
assets and other illiquid investments (collectively, “Excluded Assets”). Our firm will from time to time
provide our clients with education regarding participant loans and brokerage window programs. All
retirement plan consulting
services shall be in compliance with the applicable state laws regulating
retirement consulting services. This applies to client accounts that are retirement or other employee
benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as
amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to
provide services to such accounts, our firm acknowledges its fiduciary standard within the meaning
of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with
respect to the provision of services described therein.
Institutional Consulting:
Our firm provides Institutional Consulting to institutional clients including corporations, pensions,
endowments, unions. Institutional consulting will typically involve rendering a consultation for
clients based on the client’s financial goals and objectives. It may also include investment
management services. Consulting consists of assisting the Entity with monitoring and reviewing their
investment goals and investment policy statement. As the needs of the Entity dictates, areas of
advising include:
• Advice with respect to the establishment or refinement of an investment policy and its
periodic review thereafter;
• Asset-based asset allocation studies, as reasonably requested, presented in the format
normally utilized by TRG Retirement Plan Consultants for its other clients or in any other
format mutually agreed upon by the parties;
• Market overview addressing the major markets, indices, sectors and the economic statistics
that are affecting them;
• General education to Institutional Client participants;
• An in-depth portfolio summary, including fund and benchmark returns, style analysis and
overall portfolio return;
• A detailed examination of each fund within the Account, including performance numbers
versus the category and index, manager style drift, risk/return, standard deviation, Sharpe
ratio, upside and downside capture and fund allocation. This Agreement does not guarantee
the future performance or results of any investment option recommended or reviewed; and
ADV Part 2A – Firm Brochure Page 6 TRG Investment Advisors
• Searching for and assisting in selecting investment managers and custodians, as reasonably
requested, ongoing review and evaluation of managers and custodians, and recommending
new or replacement managers and custodians as necessary.
We will conduct strategic planning sessions to review current performance reports and establish
future objectives and strategies for the Account. In performing the foregoing services, our firm
acknowledges that it will be acting as a fiduciary to the Entity pursuant to the Investment Advisors
Act of 1940. Our firm does not manage assets as part of this service.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Comprehensive Portfolio Management
clients, Asset Management clients as well as our 529 Account Management clients. General
investment advice will be offered to our Retirement Plan Consulting clients.
Each 529 Account Management, Asset Management and Wrap Comprehensive Portfolio Management
client has the opportunity to place reasonable restrictions on the types of investments to be held in the
portfolio. Restrictions on investments in certain securities or types of securities may not be possible
due to the level of difficulty this would entail in managing the account.
Participation in Wrap Fee Programs
Our firm offers and sponsors a wrap fee program. Wrap Comprehensive Portfolio Management
services are only offered through wrapped accounts, which are managed on an individualized basis
according to the client’s investment objectives, financial goals, risk tolerance, etc. Please see our Part
2A, Appendix 1 (the “Wrap Fee Program Brochure”) for more information.
Regulatory Assets Under Management
Our firm manages $91,716,230 on a discretionary basis and $821,250,065 on a non-discretionary
basis for a total of $912,966,295 as of December 31, 2023.