Description of True Wealth Advisory Group, LLC
True Wealth Advisory Group, LLC (“TWAG” or the “Firm”), formed in October 17, 2017, is organized as a
limited liability company ("LLC") under the laws of the State of Delaware. TWAG is wholly owned by TWAG
Holdings, Inc. which in turn is wholly owned by Marc Shachtman, our founder and Chief Executive Officer
(“CEO”). Mr. Shachtman also serves as TWAG’s Chief Investment Officer (“CIO”). Since February 2, 2022,
TWAG has been registered as an investment adviser with the U.S. Securities and Exchange Commission (“SEC”).
Prior to the effective date or our registration, TWAG’s primary location and places of business are based in Florida.
As used in this Form Part 2A Disclosure Brochure (or “Disclosure Brochure”), True Wealth Advisory Group, LLC
is also referred to as “TWAG,” “we," "our," and "us," and, as used in this Disclosure Brochure, “client” is also
referred to as “you," "your," and any prospective client.
Prior to TWAG rendering any advisory services, clients are required to enter into one or more written agreements
with TWAG setting forth the relevant terms and conditions of the advisory relationship (the “Advisory
Agreement”).
Services Offered
Clients can retain TWAG to provide discretionary investment management services, non-discretionary investment
management services, and consulting services to them. For discretionary investment management services,
TWAG’s clients are provided these services through the True Wealth Advisory Group Wrap Fee Program (the
“Program”), which is described in more detail in the True Wealth Advisory Group Wrap Fee Program Brochure
(the “Wrap Brochure”). Discretionary investment services permit TWAG to implement suitable investment
recommendations on your behalf pursuant to the terms of the advisory agreement thereby allowing our Firm to
execute transactions in your advisory account without prior notification and approval for each recommended
transaction. Non-discretionary investment services are offered through an investment management agreement also
and permit the client the ability to approve or decline each investment recommendation from TWAG prior to our
Firm effectuating the transaction. Clients retaining TWAG for consulting services may do so through a consulting
agreement that is provided to them. For assets in the Program, TWAG is responsible for implementing any of its
recommendations and managing the client’s assets on an ongoing basis. TWAG’s clients are offered custodial
services for the securities and monies applicable to their advisory accounts through qualified independent
custodians (“custodian(s)”) for which TWAG has relationships including, Charles Schwab & Co. (“Schwab”).
Schwab is an SEC-registered broker-dealer and FINRA/SIPC member. TWAG also maintains a custodian
relationship agreement with Interactive Brokers, LLC, a SEC-registered broker-dealer and FINRA/SIPC member.
Additionally, TWAG has an arrangement with the following organizations to provide custody services for investors
that invest in virtual currencies: Gemini Trust Company (“Gemini”), Alto Solutions, Inc. d/b/a AltoIRA and
NuView Trust Company.
TWAG receives fees for its services as described in Item 5: Fees and Compensation. TWAG’s Investment
Consulting Agreement allows TWAG to amend the agreement without the requirement to obtain a signature from
the client provided our Firm provides advance notification, in writing, within thirty (30) of executing such changes.
In addition, the agreement was modified in regard to the liability incurred by TWAG to the extent permitted under
applicable laws.
TWAG provides investment consulting services to its clients through which TWAG may, as negotiated with a
client, review a client’s investment portfolio or certain investments contained within the portfolio. Through the
investment consulting arrangement, TWAG may make recommendations with respect to existing or new
investments for the portfolio. Nonetheless, under the consulting agreement, TWAG may choose to collaborate in
the implementation of its recommendations or managing the client’s assets, and clients are free to accept or reject
TWAG’s recommendations. Clients are generally responsible for implementing TWAG’s recommendations and
have the freedom to select their own investment adviser, broker-dealer or other financial institution to implement
any recommendations. TWAG uses custodian partners to support the advisory services offered. TWAG receives
fees for its services as described in Item 5: Fees and Compensation.
As of February 29, 2024, TWAG managed approximately $197,255,963 in regulatory assets under management
(“RAUM”), including $182,076,350 on a discretionary basis and $15,179,613 on a non-discretionary basis. TWAG’s
Wrap Program, as of February 29, 2024, consisted of approximately $111,872,331 in managed assets. Our Firm, as of
February 29, 2024, also had approximately $$8,758,699 in additional assets under advisement.
Types of Investments
Our investment recommendations are not limited to any specific product or service offered by a broker dealer, or
insurance company, and will generally include advice regarding the advisability of owning equity securities,
corporate debt securities, certificates of deposit, municipal securities, annuities, mutual fund shares, exchange-
traded products (e.g. ETFs, ETNs), United States government or government agency securities, money market
funds, cash and cash equivalents, REITs, MLPs, interests in partnerships investing in real estate, interests in
partnerships investing in oil and gas interests, interests in partnerships investing in private equity investments,
listed options, private placement investments, and virtual currencies (e.g. cryptocurrencies). Some, but not all, of
these types of investments can be managed by TWAG through a discretionary investment management services
agreement (or “Advisory Agreement”) or under the Program, while others can only be advised on via TWAG’s
consulting agreement.
Subject to our discretion, we may also provide advice on any type of investment held in your portfolio at the
inception of our advisory relationship.
Use of Independent Managers
TWAG can select, or recommend, certain third-party independent managers (“Independent Managers”) to
actively manage a portion of client assets. When selecting or recommending certain Independent Managers,
TWAG delegates its authority to the Independent Manager and no separate client agreement is necessary.
TWAG may provide the client with the Independent Manager’s disclosure brochure.
Certain Independent Mangers will set forth the specific terms and conditions under which a client engages an
Independent Manager in a separate written agreement with the designated Independent Manager. In those
cases, clients will also receive the written disclosure documents of the respective Independent Managers
engaged in managing their assets.
TWAG evaluates a variety of information about Independent Managers, which may include 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, TWAG seeks to assess the Independent
Managers’ investment strategies, past-performance, and risk results in relation to its clients’ individual
portfolio allocations and risk exposure. TWAG may also take into consideration each Independent Manager’s
management style, returns, reputation, financial strength, reporting, pricing, and research capabilities, among
other factors.
TWAG continues to provide services relative to the discretionary recommendation of one or more of the
Independent Managers selected for the client. On an ongoing basis, TWAG monitors the performance of those
accounts being managed by Independent Managers and seeks to ensure their strategies and target allocations
remain aligned with its clients’ investment objectives and overall best interests.
Since our investment strategies and advice are based on each client’s specific financial situation, the investment
advice we provide to you may be different or conflict with the advice we give to other clients regarding the same
security or investment. Our investment advice and advisory services are tailored to meet the individual needs of
clients. TWAG chooses investments and/or investment strategies it deems appropriate given each of our client’s
investment objectives and risk tolerance. The selection of an Independent Manager subjects TWAG to a conflict of
interest exists as this arrangement requires a portion of the Management Fee to be compensated to the Independent
Manager(s) thereby resulting in lower remuneration to TWAG, in general, than occurs when TWAG provides
advisory services without the use of an Independent Manager(s).
Reasonable Restrictions
TWAG, and/or the Independent Managers used, allows clients to place reasonable restrictions on investments in
certain securities, types of securities, or industries. To implement a restriction, the client (or authorized individual)
may request, in writing, a limitation or restriction on our discretionary authority with respect to certain securities,
types of securities, or industries, to not be bought or sold. All changes to existing restricted security elections must
be submitted to us by the client, in writing, with instructions to TWAG or the Independent Manager to make
changes. Clients are reminded that these changes will not be considered in effect until the client receives such
confirmation from TWAG.
TWAG may elect to not accept a client’s account(s) for management if significant restrictions apply. Once received
in writing, TWAG will review the requested restrictions for “reasonableness” which will be determined in
TWAG’s sole discretion. If TWAG determines that the requested restriction is unreasonable, TWAG will notify the
client that TWAG cannot manage the account with the requested restriction. The client may, thereafter, request that
the restriction not be implemented in order to engage TWAG or the Independent Manager to manage or continue to
manage the account.
Clients should be aware that requested restrictions cannot and will not be implemented on underlying holdings used
within the client portfolio of a mutual fund, ETF or other pooled vehicle, and therefore the client’s accounts may
gain exposure to a restricted security, type of security, or industry, through the use of these vehicles. Furthermore,
TWAG does not and will not monitor the underlying holdings of pooled vehicles for restriction purposes. Clients
expressly acknowledge this limitation when engaging TWAG or an Independent Manager to continue managing
accounts with restrictions. If restrictions create significant limitation on TWAG or an Independent Manager’s
ability to efficiently and/or effectively manage a client’s portfolio, TWAG may elect to not accept the client’s
account(s) for management.
Finally, TWAG will not act with discretion with respect to restricted securities. Therefore, trades for these
restricted securities always require prior approval from the client.
True Wealth Advisory Group Wrap Fee Program
Program assets that are directly managed and traded by TWAG, or an Independent Manager, using institutional
access granted by Schwab, and generally consist of different investments and objectives than as compared to
Consulting assets, which we cannot directly manage, and which are generally limited in scope to certain alternative
investments and targeted objectives. Clients in the Program pay a single “Wrap Fee”, from which TWAG receives
Advisory Fees, but which also covers other costs such as transaction fees, wire fees, maintenance fees, custodial
fees, and other administrative costs. Please refer to Item 5: Fees and Compensation for more information on fees
and how we are compensated.
Private Placement Insurance Products - Only Available to Accredited Investors, Qualified Clients and
Qualified Purchasers
TWAG can act as an adviser to the Investment Manager (“Manager”) of Insurance Dedicated Funds (IDF) held in a
Private Placement Insurance Products (Life Insurance – “PPLI” or Variable Annuities – “PPVI”). The objective of
utilizing these structures is to seek investment returns that accumulate on a tax-deferred basis (through variable
annuities) or are fully exempt from income tax (via life insurance). These PPLI/PPVI offerings are available to
Accredited Investors, Qualified Clients and Qualified Purchasers.
TWAG is responsible for providing investment advice to the Manager of the IDFs under an executed Investment
Consulting Agreement with the PPLI/PPVI Manager, on behalf of the client. However, TWAG is not responsible
for managing such assets, and the Manager is responsible for the implementation of such advice. Therefore, the
Manager is always free to accept or reject TWAG’s recommendations. The Manager is selected by the Insurance
Company to manage client assets.
TWAG is not affiliated with the selected Manager or Insurance Company and does not receive any commission or
compensation of any kind from the insurance company.
TWAG collects a fee on the assets under advisement as described under the Investment Consulting Fee description
as shown in Item 5: Fees and Compensation.
Rollovers
As part of our investment advisory services to you, we may recommend that you withdraw the assets from your
employer's retirement plan and roll the assets over to an individual retirement account ("IRA") that we will manage
on your behalf. Such recommendations shall be undertaken in accordance with our fiduciary obligations and
applicable Employee Retirement Income Security Act of 1974 (“ERISA”) rules. If you elect to roll the assets to an
IRA that is subject to our management, we will charge you an asset-based fee as set forth in the Advisory
Agreement you executed with our Firm. This practice presents a conflict of interest because persons providing
investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating
fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or
otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have
the assets in an IRA managed or consulted by our Firm.