General Information Turtle Creek Wealth Advisors, LLC, a Texas limited liability company, was formed in June 2022.
Advisory Services The Adviser provides portfolio management, including design, consultation, and implementation; financial planning; estate and tax planning; family governance and education; personal cash flow and portfolio projections; multi-generational wealth management; private banking services; risk management and insurance planning; charitable giving strategies and foundation management; and family office services to individuals, including high net worth individuals, trusts, and foundations.
At the outset of each client relationship, the Adviser spends time with the client, asking questions, discussing the client’s investment experience and financial circumstances, and broadly identifying major goals of the client. Specifically, the Adviser may discuss with the client cash flows, required distributions, significant life events, risk tolerance, and return expectations.
PortfolioManagement Based on its review of the information provided by the client, the Adviser generally develops with each client an understanding of the client’s financial circumstances, goals, time horizons, and the client’s risk tolerance level (the “Financial Profile”), as well as the client’s investment objectives and guidelines (the “Investment Plan”).
The Financial Profile reflects the client’s current financial situation and a look to the future goals of the client. The Investment Plan outlines the types of investments the Adviser will make on behalf of the client based on the Adviser’s own research and analysis to meet those goals. The Adviser will monitor the Investment Plan and manage and revise the Investment Plan based on a client’s changing goals and life circumstances over time. The elements of the Financial Profile and the Investment Plan are discussed periodically with each client but are not necessarily written documents.
To implement the client’s Investment Plan, the Adviser will manage the client’s investment portfolio on a discretionary or a non-discretionary basis pursuant to an investment advisory agreement with the client. As a discretionary investment adviser, the Adviser will have the authority to supervise and direct the portfolio without prior consultation with the client. Clients who choose a non-discretionary arrangement must be contacted prior to the execution of any trade in the account(s) under management. This may result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio.
Notwithstanding the foregoing, clients may impose certain written restrictions on the Adviser in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in an investment portfolio at the commencement of the relationship. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client’s investment portfolio. Each client should also note that his or her investment portfolio is treated individually by considering each purchase or sale for the client’s account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals, time horizons, and/or risk tolerance may differ, and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of the Adviser.
SeparateAccountManagers In accordance with the Investment Plan for a client, the Adviser expects to utilize one or more sub- advisers (each, a “Manager”) to manage all or a portion of a client’s portfolio. Having access to various Managers offers a wide variety of manager styles and offers clients the opportunity to utilize more than one Manager if necessary to meet the needs and investment objectives of the client. The Adviser will select the Manager(s) it deems most appropriate for the client. Factors that the Adviser considers in selecting Managers generally includes the client’s stated investment objective(s), management style, performance, risk level, reputation, financial strength, reporting, pricing, and research.
The Manager(s) will generally be granted discretionary trading authority to provide investment advisory services for the portfolio. Under most circumstances, the Adviser retains the authority to terminate the Manager’s relationship or to add new Managers without specific client consent.
In any case, with respect to assets managed by a Manager, the Adviser’s role will be to monitor the overall financial situation of the client, to monitor the investment approach and performance of the Manager(s), and to assist the client in understanding the investments of the portfolio.
DirectPortfolioManagement Under certain circumstances, the Adviser will internally manage all or a portion of a client’s portfolio rather than utilizing one or more Managers. Specifically, the Adviser will internally manage the following strategies with respect to a client’s portfolio if such strategies are utilized based on the client’s Investment Plan:  TheDividendAppreciationStrategy: The Dividend Appreciation Strategy (DAPPR) is built on the foundation that the cohort of companies who pay a dividend and have a history of growing those dividends over time will outperform companies with other dividend policies. The investment thesis of DAPPR seeks long-term capital appreciation and cash flow generation primarily through investments in divided-growth, U.S. based stocks diversified across economic sectors,

shifting themes, and investment styles.
 TheFocusStrategy: The Focus Strategy (Focus) aims to outperform the S&P 500 Index by focusing on the industries that the Adviser believes have the best opportunity to outperform the market through different economic cycles. The investment thesis behind Focus is quite simple: own the economic sectors that are in favor and avoid the sectors that are out of favor. By taking a more targeted approach, the goal is to outpace the market in times of growth and protect capital in challenging markets. The process behind Focus is intentionally purely quantitative, as to remove biases such as human emotion, critical behavior, and external perception.
The Adviser may develop additional strategies that it will internally manage in the future, in which event all affected clients will be notified.
FinancialPlanning The Adviser generally provides financial planning services to those clients in need of such services in conjunction with portfolio management services. The Adviser’s financial planning services normally include advice that addresses one or more areas of a client’s financial situation, such as modeling the outcomes of business decisions and helping to understand the context around business decisions, risk management, budgeting and cash flow controls, and investment portfolio design and ongoing management. The Adviser will revisit the client’s financial planning needs throughout the entire relationship as appropriate.
EstateandTaxPlanning The Adviser will coordinate with estate attorneys and tax professionals to craft and manage sophisticated wealth strategies that are designed to efficiently transfer wealth and reduce tax burdens. Estate plans and tax strategies are fully implemented based on interaction and partnership with clients’ outside legal and tax advisors. This includes the review and design of estate plans, tax-advantaged strategies, and asset protection planning.
The Adviser will also coordinate with tax professionals to manage overall income tax considerations for individuals and entities associated with entity formation and management, asset transactions, and general income tax planning.
FamilyGovernanceandEducation The Adviser works closely with families to help them make informed decisions regarding their wealth. Additionally, the Adviser provides such families with assistance relating to communication strategies regarding family wealth and the development of joint decision making policies around commonly owned family assets, in an effort to minimize conflicts.
PersonalCashFlowandPortfolioProjections The Adviser performs hypothetical projections for both personal cash flows and portfolios by working with individuals to determine inputs and assumptions based on historical figures and the expected return of their unique portfolios.
Multi-GenerationalWealthManagement The Adviser assists families in wealth creation, maintenance, and the transfer and development of relationships with each generation to educate, communicate, and help ensure the smooth transition of assets.
PrivateBankingServices The Adviser supports clients’ personal banking needs by recommending and/or coordinating with third party banks to provide deposit services, streamlined securities-based lines of credit, aircraft lending, mortgages, and other personal credit facilities.
RiskManagementandInsurancePlanning The Adviser coordinates with third parties to review life, long-term care, and disability insurance policies and/or to help design and implement new policies appropriate for clients’ particular risks and goals.
CharitableGivingStrategiesandFoundationManagement The Adviser counsels clients on tax-efficient strategies for charitable giving. The Adviser spends considerable time reviewing giving options and can assist clients in choosing meaningful recipients for their gifts and making and recording such gifts. The Adviser seeks to help families create the legacy they desire through direct gifts to specific charitable organizations or to legacy charitable entities, such as donor advised funds, private foundations, or charitable trusts.
FamilyOfficeServices The Adviser provides ongoing oversight and administration, including assuming the day-to-day hassles of insurance review and payment and coordinating with other professional service providers, such as lawyers, accountants, and insurance providers.
FundInvestment AdvisoryServices The Adviser provides investment advisory services to pooled investment vehicles (each, a “Fund”, and collectively, the “Funds”) that are exempt from registration under the Investment Company Act of 1940, as amended (the “1940 Act”), and whose securities are not registered under the Securities Act of 1933, as amended (the “Securities Act”). In providing investment advisory services to the Funds, the Adviser does so indirectly though Turtle Creek Capital, LLC (the “Relying Adviser”), a related person of the Adviser.
The Relying Adviser serves as the manager of the following Funds: (i) TCWA Esperanza GoM LLC, a Delaware limited liability company; and (ii) TCWA Turns LLC, a Delaware limited liability company. The Relying Adviser is wholly owned by the Adviser. All supervised persons acting on behalf of the Relying Adviser are also supervised persons of the Adviser. In addition, the Adviser and the Relying Adviser operate under a single code of ethics (the “Code”) and compliance manual that is administered by the Adviser’s Chief Compliance Officer (the “CCO”). Because the Relying Adviser is a “Relying Adviser” of the Adviser, all references to the “Adviser” in this Brochure include the Relying Adviser.
Principal Owners David Miller, Kyle Miller, and Meredith Bebee are the principal owners of the Adviser, who own the Adviser through the David Bruce Miller 2022 Trust, the Kyle Miller Family 2014 Trust, and the Meredith Lee Miller 2006 Lifetime Trust, respectively.
Type and Value of Assets Currently Managed As of December 31, 2023, the Adviser managed approximately $801,233,797 on a discretionary basis and $104,389,499 on a non-discretionary basis.