A. Description of the Advisory Firm
Terraform Wealth, LLC (hereinafter “TWL”) is a Limited Liability Company organized in
the State of Texas. The firm was formed in January 2023, and the principal owner is
Terraform Holdings, LLC.
B. Types of Advisory Services
Portfolio Management Services
TWL offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. TWL creates an Investment
Policy Statement for each client, which outlines the client’s current situation (income, tax
levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a
portfolio that matches each client's specific situation. Portfolio management services
include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
TWL evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. TWL will request discretionary authority from clients in order to
select securities and execute transactions without permission from the client prior to each
transaction. Risk tolerance levels are documented in the Investment Policy Statement,
which is given to each client.
TWL seeks to provide that investment decisions are made in accordance with the fiduciary
duties owed to its accounts and without consideration of TWL’s economic, investment or
other financial interests. To meet its fiduciary obligations, TWL attempts to avoid, among
other things, investment or trading practices that systematically advantage or
disadvantage certain client portfolios, and accordingly, TWL’s policy is to seek fair and
equitable allocation of investment opportunities/transactions among its clients to avoid
favoring one client over another over time. It is TWL’s policy to allocate investment
opportunities and transactions it identifies as being appropriate and prudent, including
initial public offerings ("IPOs") and other investment opportunities that might have a
limited supply, among its clients on a fair and equitable basis over time.
TWL has discretion to choose third-party investment advisers to manage all or a portion
of the client's assets. Before selecting other advisers for clients, TWL will always ensure
those other advisers are properly licensed or registered as an investment adviser. TWL
conducts due diligence on any third-party investment adviser, which may involve one or
more of the following: phone calls, meetings and review of the third-party adviser's
performance and investment strategy. TWL then makes investments with a third-party
investment adviser by investing with the third-party adviser. These investments may be
allocated either through the third-party adviser's fund or through a separately managed
account managed by such third party adviser
on behalf of TWL's client. TWL may also
allocate among one or more private equity funds or private equity fund advisers. TWL
will review the ongoing performance of the third-party adviser as a portion of the client's
portfolio.
Services Limited to Specific Types of Investments
TWL generally limits its investment advice to mutual funds, fixed income securities, real
estate funds (including REITs), insurance products including annuities, equities, hedge
funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors),
treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities,
venture capital funds and private placements. TWL may use other securities as well to
help diversify a portfolio when applicable.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. We also have a fiduciary
duty under the Investment Advisers Act of 1940 with respect to all client accounts. The
way we make money creates some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead
of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in
your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
C. Client Tailored Services and Client Imposed Restrictions
TWL 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 TWL on behalf of the client. TWL may use model allocations together with a
specific set of recommendations for each client based on their personal restrictions, needs,
and targets. Clients may not impose restrictions in investing in certain securities or types
of securities in accordance with their values or beliefs.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees and transaction costs. TWL does not participate in wrap fee
programs.
E. Assets Under Management
TWL has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$173,240,017 $0 December 2023