A. Description of the Advisory Firm
B. Types of Advisory Services
TMW evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. Risk tolerance levels are documented in the Investment Policy
Statement, which is given to each client.
TMW mainly uses equity securities, exchange traded funds, mutual funds, U.S.
government securities, corporate debt securities, municipal securities, and options
strategies in its portfolio management programs. In limited cases, we may also
recommend investments in limited partnerships such as hedge funds and private equity
funds.
Pension Consulting Services
TMW offers consulting and advisory services for employer-sponsored retirement plans
that are designed to assist plan sponsors of employee benefit plans (“Sponsor(s)”). TMW
may also assist Sponsors with enrollment and/or providing investment education to plan
participants and beneficiaries. Clients may choose to use any or all of these services:
Selection of Investment Vehicles
TMW will review various investments, consisting of one or all of the following: individual
equities, bonds, other investment products and mutual funds (both index and managed)
to determine which of these investments are appropriate to implement the client's
Investment Policy Statement. The number of investments to be recommended will be
determined by the client, based on the client’s Investment Policy Statement.
Monitoring of Investment Performance
Client investments will be monitored continuously based on the procedures and timing
intervals outlined in the Investment Policy Statement. Although TMW will not be
involved in any way in the purchase or sale of these investments, TMW will supervise the
client's portfolio and will make recommendations to the client as market factors and the
client's needs dictate.
Employee Communications
For pension, profit sharing and 401(k) plans where the individual account participant
exercises control over assets in his/her own account (hereinafter ''self-directed plans''),
TMW also provides educational support and investment workshops designed for the Plan
participants. The nature of the topics to be covered will be determined by TMW and the
client under the guidelines established in ERISA Section 404(c). The educational support
and investment workshops will NOT provide Plan participants with individualized,
tailored investment advice or individualized, tailored asset allocation recommendations.
Other pension consulting services are available on request. All of our pension consulting
services, whether general or customized, will be outlined in an Agreement that shows the
services that will be provided and the fees that will be charged for those services.
Retirement Plan Rollover Recommendations - When TMW provides investment advice about
your retirement plan account or individual retirement account (“IRA”) including whether
to maintain investments and/or proceeds in the retirement plan account, roll over such
investment/proceeds from the retirement plan account to a IRA or make a distribution
from the retirement plan account, we acknowledge that TMW is a “fiduciary” within the
meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the
Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement
accounts. The way TMW makes money creates conflicts with your interests so TMW
operates under a special rule that requires TMW to act in your best interest and not put
our interest ahead of you.
Under this special rule’s provisions, TMW must as a fiduciary to a retirement plan
account or IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (e.g.,
give prudent advice);
• Never put the financial interests of TMW ahead of you when making
recommendations (e.g., give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that TMW gives advice that is in
your best interest;
• Charge no more than is reasonable for the services of TMW; and
• Give Client basic information about conflicts of interest.
To the extent We recommend you roll over your account from a current retirement plan
account to an individual retirement account managed by TMW, please know that TMW
and our investment adviser representatives] have a conflict of interest.
We can earn increased investment advisory fees by recommending that you roll over your
account at the retirement plan to an IRA managed by TMW. We will earn fewer
investment advisory fees if you do not roll over the funds in the retirement plan to an IRA
managed by TMW.
Thus, our investment adviser representatives have an economic incentive to recommend a
rollover of funds from a retirement plan to an IRA which is a conflict of interest because
our recommendation that you open an IRA account to be managed by our firm can be
based on our economic incentive and not based exclusively on whether or not moving the
IRA to our management program is in your overall best interest.
We have taken steps to manage this conflict of interest. We have adopted an impartial
conduct standard whereby our investment adviser representatives will (i) provide
investment advice to a retirement plan participant regarding a rollover of funds from the
retirement plan in accordance with the fiduciary status described below, (ii) not
recommend investments which result in TMW receiving unreasonable compensation
related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose
compensation received by TMW and our supervised persons and any material conflicts of
interest related to recommending the rollover of funds from the retirement plan to an IRA
and refrain from making any materially misleading statements regarding such rollover.
When providing advice to your regarding a retirement plan account or IRA, our
investment advisor representatives will act with the care, skill, prudence, and diligence
under the circumstances then prevailing that a prudent person acting in a like capacity
and familiar with such matters would use in the conduct of an enterprise of a like
character and with like aims, based on the investment objectives, risk, tolerance, financial
circumstances, and a client’s needs, without regard to the financial or other interests of
TMW or our affiliated personnel.
Financial Planning Services
We offer broad based financial planning which includes a variety of services, mainly
advisory in nature, regarding management of financial resources. Such management is
based upon an analysis of the client’s individual needs and begins with an initial
complementary consultation. Upon being hired to do a complete financial plan, we collect
and analyze all documentation, we provide a written financial plan designed to achieve
the client’s financial goals and objectives. In this way, TMW assists the client in
developing a strategy
for the successful management of income, assets, and liabilities. In
general, financial planning services may include any one or all of the following:
• Cash Flow Analysis – Assessment of a client’s present financial situation by
collecting information regarding net worth and cash flow statements, tax returns,
insurance policies, investment portfolios, pension plans, employee benefit
statements etc. The Firm advises on ways to reduce risk, coordinate and organize
records, and estate information.
• Retirement Analysis – Identification of a client’s long-term financial and personal
goals and objectives including advice for accumulating wealth for retirement
income or appropriate distribution of assets following retirement. Tax
consequences and implications are identified and evaluated.
• Insurance Analysis – Includes risk management associated with advisory
recommendations based on a combination of insurance types to meet a client’s
needs, e.g., life, health, disability, and long-term care insurance. This will
necessitate an analysis of cash needs of family at death, income needs of surviving
dependents, and disability income analysis.
• Portfolio Analysis/Investment Planning – We provide investment alternatives,
including asset allocation, and effect on a client’s portfolio. We evaluate economic
and tax characteristics of existing investments as well as their suitability for a
client’s objectives. We identify and evaluate tax consequences and their
implications.
• Education Savings Analysis – Alternatives and strategies with respect to the
complete or partial funding of college or other post-secondary education.
• Estate Analysis – We provide advice with respect to property ownership,
distribution strategies, estate tax reduction, and tax payment techniques.
The recommendations and solutions are designed to achieve the client’s desired goals,
subject to periodic evaluation of the financial plan which may require revision to meet
changing circumstances. Financial plans are based on a client’s financial situation based
on the information provided to the Firm. We should be notified promptly of any change
to a client’s financial situation, goals, objectives or needs.
Clients can also request financial planning services that cover a specific area, such as
retirement or estate planning, asset allocation analysis, manager due diligence and 401(k)
platform due diligence. We offer consultative services where we set an appointment to
meet with you for financial planning advice for an hourly fee.
You may choose to accept or reject our recommendations. If you decide to proceed with
our recommendations, you may do so either through our investment advisory services or
by using the advisory/brokerage firm of your choice.
Educational Seminar/Workshops
TMW is a strong advocate of consumer education and financial literacy. To support this
mission, TMW may provide seminars to consumers, corporations, associations, nonprofit
organizations and community and religious groups on a variety of personal finance
topics. They are designed to explain complex financial concepts in plain English in a way
that is educational, informational and entertaining. These
seminars/workshops/presentations will be provided on an ad hoc basis. The fees for the
seminars/workshops/presentations will be charged in advance and payable by check,
cash, or PayPal. Fees range from $25 to $5,000 per event.
Services Limited to Specific Types of Investments
TMW mainly uses equity securities, exchange traded funds, mutual funds, U.S.
government securities, corporate debt securities, municipal securities, and options
strategies in its portfolio management programs. In limited cases, we may also
recommend investments in limited partnerships such as hedge funds and private equity
funds. TMW may use other securities as well to help diversify a portfolio when
applicable.
TMW will tailor a program for each individual client. This will include an interview
session to get to know the client ’s specific needs and requirements as well as a plan that
will be executed by TMW on behalf of the client. TMW may use model allocations together
with a specific set of recommendations for each client based on their personal restrictions,
needs, and targets. Clients may impose restrictions in investing in certain securities or
types of securities in accordance with their values or beliefs. However, if the restrictions
prevent TMW from properly servicing the client account, or if the restrictions would
require TMW to deviate from its standard suite of services, TMW reserves the right to end
the relationship.
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and other administrative
fees. TMW does not participate in any wrap fee programs.
TMW has the following assets under management:
C. Client Tailored Services and Client Imposed Restrictions
D. Wrap Fee Programs
E. Assets Under Management
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$127,010,589 $5,088,313 January 31, 2023
Investment Supervisory Services Fees
Total Assets Under Management Annual Fees
$0 - $500,001 1.50%
$500,001 - $1,000,000 1.25%
$1,000,001 - $5,000,000 1.00%
$5,000,001 - $10,000,000 0.75%
$10,000,001 And Up 0.50%
The advisory fee is calculated using the value of the assets in the Account on the last business
day of the prior billing period. The current fee schedule is attached as Exhibit II of the
Investment Advisory Contract. (IAC)
Adjustments to standard fees may be negotiated with clients who have more than one related
account owned by family, friends, or business associates, unusually sophisticated or simplified
investment needs & strategies, or where accounts are tax qualified or may require tax harvesting.
A full refund of TMW’s fee may be requested within five business days of signing the IAC.
Thereafter, clients may terminate the IAC generally with 30 days' written notice.
Educational Seminar/Workshops
The fees for the /workshops/presentations will be charged in advance and payable by
check, cash, or PayPal. Fees range from $25 to $5,000 per event. These fees are negotiable.
The fee is determined for educational seminar/workshops by the type
of event/presentation/workshop that is presented and the clients who attend the
seminars whether it be consumers, corporations, associations, nonprofit organizations
and community and religious groups. The fees are payable in advance. Clients may
receive a full refund immediately upon termination of service.
The fee per employee for travel, lodging and per diem may be included in the fees charged
for the educational seminar/workshop. For an individual, the fee for the seminar may be
between $25- $500. The fee may be up to $5,000 should a corporation or business utilize
the services of TMW for providing a educational seminar for their employees.