A. Ownership/Advisory History
Titleist Asset Management, LLC (referred hereinafter to as “TAM” or the “firm”) was incorporated
in the State of Texas in 2022, but the firm’s principals and investment professionals have been
providing investment management services through one or more TAM affiliates since 2003. TAM
is registered with the SEC as a Registered Investment Advisor (“RIA”). Mr. Byron L. Fields and Mr.
Joe-Ben O’Banion control TAM.
As of 03/27/2024, all assets being serviced by TAM including both the RIA (TAM) and BD (Titleist
Capital, Inc.) total $1,464,842,367. At the present time, the investment advisory assets under
management are $1,401,798,353. The brokerage assets being serviced total $63,044,014. This
amount is comprised of securities such as mutual funds, annuities, and alternative investments.
B. Advisory Services Offered
Investment Management Services
Investment Management Services begin by TAM assisting each new client in determining the
client's investment objectives. TAM will analyze each client's current investments, investment
objectives, goals, time horizon, financial circumstances, investment experience, investment
restrictions and limitations, and risk tolerance to implement a portfolio consistent with such
investment objectives, goals, risk tolerance and related financial circumstances. In addition, TAM
may utilize third-party software to analyze individual security holdings and separate account
managers utilized within the client’s portfolio.
Once a portfolio is established, the Investment Advisor Representative (“IAR”), in a fiduciary
capacity, manages each client's investments in a manner consistent with the client’s objectives
and risk tolerance. When discretionary authority is granted by a client, TAM is free to select the
securities to buy and sell, the amount to buy and sell, and when to buy and sell. TAM will be
restricted to having limited trading authorization.
TAM offers a customized and individualized investment program for clients. A specific asset
allocation strategy is crafted to focus on the specific client’s goals and objectives. TAM offers the
following allocation strategies (“Allocation Strategies”), which are described in detail in Item 8 of
this brochure:
▪ Income Portfolio
▪ Conservative Portfolio
▪ Balanced Portfolio
▪ Growth Portfolio
▪ Capital Appreciation Portfolio
The Allocation Strategies are monitored and overseen by the firm’s investment committee. The
investment committee comprises Byron Fields, Austin Graff, and Joe-Ben O’Banion.
Clients have the right to provide the firm with any reasonable investment restrictions that should
be imposed on the management of their portfolio, and should promptly notify the firm in writing
of any changes in such restrictions or in the client's personal financial circumstances, investment
objectives, goals and tolerance for risk. TAM will remind clients of their obligation to inform the
firm of any such changes or any restrictions that should be imposed on the management of the
client’s account. TAM will also contact clients at least annually to determine whether there have
been any changes in a client's personal financial circumstances, investment objectives and
tolerance for risk.
Financial Planning Services
TAM provides financial planning services to meet clients’ goals consistent with their financial
status, investment objectives, and tax status. These services include, but are not limited to:
▪ Financial planning for retirement, education, major purchases, debt management, savings
needs and goals, insurance needs, long-term care needs, business planning, and legacy,
succession, and estate planning.
▪ Budget considerations for immediate and future needs
▪ Reviewing employer-provided benefits / planning benefits for self-employed
▪ Analyzing financial impact of potential life changes or options to help the client make
decisions
TAM will obtain and analyze the necessary financial data from the client to provide the above-
mentioned services. The client will receive a written plan and recommendations based on their
current financial position and information obtained in meetings with the client.
The client will be required to complete an overall assessment or questionnaire to assist TAM in
formulating the client’s financial planning objectives. The client’s active participation in the
formulation and implementation of the financial planning objectives is required for TAM's
preparation of the client’s financial plan. Certain documents such as financial statements, tax
returns, etc., may be requested by TAM to perform a more complete and thorough evaluation of
client’s financial position.
After completing the initial financial planning process, the client may choose to continue using
TAM to help implement the recommendations and strategies in the financial plan. We are
available to assist in a variety of ways. If you specifically request, TAM, acting in a sales capacity,
will recommend specific insurance and products through which your financial plan can be
implemented. Purchasing insurance products may result in additional fees or commissions. We
will work with other professionals that the client specifically requests in order to help facilitate the
implementation of the plan; such request must be made in writing.
TAM does not provide tax or legal advice, and recommends clients consult with their tax and/or
legal professional for such guidance. TAM is not qualified to prepare accounting or legal
documents for the implementation of client’s financial plans which includes but is not limited to
legal advice, opinions, determinations, documents, or tax
returns and accounting documents.
Retirement Plan Investment Advisory Consulting Services
TAM provides investment advisory consulting services to qualified 3(21) and 3(38) plans.
3(21) Retirement Plans
TAM provides non-discretionary ERISA Section 3(21) services to its Plan clients that may involve
one or more of the following:
▪ TAM will select a diverse portfolio of securities and inform the Plan of the securities
selected.
▪ The Plan will select, monitor, and change the securities included in the portfolios offered
to Plan Participants from time-to-time as determined by the Plan in its sole discretion.
▪ TAM will serve as a non-discretionary investment manager of the Plan as defined in Section
3(21) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”),
when it is providing the services described above and acknowledges that it is a co-fiduciary
to the Plan in providing such services.
▪ TAM will act as a non-discretionary, co-fiduciary only with respect to this investment
management function, and not in regard to the administration of the Plan. The Plan
Administrator, as defined in ERISA and as appointed under the Plan document, or its
delegate, is responsible for the Plan’s administration, and any fiduciary services not
specifically delegated to TAM under the agreement.
▪ The Plan’s record-keeper will provide quarterly performance reports to the Plan
representatives regarding the performance of the products in the Plan.
3(38) Retirement Plans
TAM may provide ERISA Section 3(38) discretionary services to 3(38) Plans involve the following:
▪ TAM will select a diverse suite of investment options and inform the Plan of the securities
selected.
▪ TAM will select, monitor, and change the securities included in the portfolios offered to
Plan participants from time-to-time as determined by TAM in its sole discretion. Portfolios
generally will include multiple asset classes of mutual funds and exchange-traded funds
sponsored by established fund families. The Plan representatives acknowledge that the
selection of available investments is subject to change from time-to-time, and funds may
be merged or closed at any time without notice to TAM. In such an event, TAM will make
changes and replace closed funds when deemed necessary or desirable by TAM.
▪ In those instances in which the Plan representatives do not have an established
relationship with a qualified record-keeper, TAM will assist the Plan representatives in
establishing a relationship with an independent, qualified record-keeper on behalf of the
Plan. In such instances, TAM, from time to time, in its sole discretion, will direct the record-
keeper to rebalance account balances of Plan participants to the extent necessary to
comply with the current allocation of the TAM’s portfolios.
▪ TAM will serve as a discretionary investment manager of the Plan as defined in Section
3(38) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”),
when it is providing the services described above and acknowledges that it is a fiduciary
to the Plan in providing such services.
▪ TAM will provide discretionary fiduciary investment management services as an
investment manager for the Plan, as such term is defined in Section 3(38) of the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”).
▪ TAM will act as a discretionary fiduciary only with respect to this investment management
function, and not in regard to the administration of the Plan. The Plan Administrator, as
defined in ERISA and as appointed under the Plan document, or its delegate, is responsible
for the Plan’s administration, and any fiduciary services not specifically delegated to TAM
under this Agreement.
▪ TAM has no responsibility to provide any services and does not serve in any fiduciary
capacity with regard to the following types of assets unless such types of assets are
included in an investment option selected by the sub-adviser: employer securities, real
estate (but excluding real estate funds and publicly traded REITS), non-publicly traded
securities or assets, or other illiquid assets (collectively, “Non-Traditional Assets”). TAM has
no responsibility to provide any investment advisory services with regard to investment
options selected by the Plan representatives or any other advisor or manager on their
behalf, including, but not limited to, investments offered through an open architecture
brokerage window or an investment or investments chosen by the Plan representatives or
a third party.). The Non-Traditional Assets will be included in determining the fees payable
to TAM, and the fees will be calculated only on total plan assets.
▪ The Plan’s record-keeper will provide quarterly performance reports to the Plan
representatives regarding the performance of the products in the Plan.
C. Client-Tailored Services and Client-Imposed Restrictions
Each client’s account will be managed on the basis of the client’s financial situation and investment
objectives and in accordance with any reasonable restrictions imposed by the client on the
management of the account—for example, restricting the type or amount of security to be
purchased in the portfolio.
D. Wrap Fee Programs
TAM is the sponsor and manager for its proprietary wrap fee program, where brokerage
commissions and transaction costs are included in the asset-based fee charged to the client. TAM
provides clients the option of participating in wrap or non-wrap fee arrangements. Refer to the
ADV Part 2, Appendix 1, Wrap Fee Brochure for a full description of wrap program services and
fees.