TPW offers a variety of advisory services, which include financial planning, consulting, and investment
management services. Prior to TPW rendering any of the foregoing advisory services, clients are required
to enter into one or more written agreements with TPW setting forth the relevant terms and conditions of
the advisory relationship (the “Advisory Agreement”).
TPW filed for registration as an investment adviser in September 2023 and is owned by Andrew Schiff,
Gregory Blake, William Sterling Jr., and Deatra Vailes. As of February 7, 2024, TPW had $1,328,788,451
in assets under management; all of which is managed on a discretionary basis.
While this brochure generally describes the business of TPW, certain sections also discuss the activities of
its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a
similar status or performing similar functions), employees or other persons who provide investment advice
on TPW’s behalf and are subject to the Firm’s supervision or control.
Financial Planning and Consulting Services
TPW offers clients a broad range of financial planning and consulting services, which include any or all of
the following functions:
• Business Planning
• Cash Flow Forecasting
• Trust and Estate Planning
• Financial Reporting
• Investment Consulting
• Insurance Planning
• Retirement Planning
• Risk Management
• Charitable Giving
• Distribution Planning
• Tax Planning
• Education Planning
In performing these services, TPW is not required to verify any information received from the client or
from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely
on such information. TPW recommends certain clients engage the Firm for additional related services, its
Supervised Persons in their individual capacities as insurance agents and/or other professionals to
implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to
recommend that clients engage TPW or its affiliates to provide (or continue to provide) additional services
for compensation, including investment management services. Clients retain absolute discretion over all
decisions regarding implementation and are under no obligation to act upon any of the recommendations
made by TPW under a financial planning or consulting engagement. Clients are advised that it remains
their responsibility to promptly notify the Firm of any change in their financial situation or investment
objectives for the purpose of reviewing, evaluating or revising TPW’s recommendations and/or services.
Investment and Wealth Management Services
TPW provides clients with wealth management services which include a broad range of financial planning
and consulting services as well as discretionary management of investment portfolios.
TPW primarily allocates client assets among various individual debt and equity securities, privately placed
securities (including debt, equity, interests in pooled investment vehicles and other alternative investments)
and independent investment managers (“Independent Managers”) in accordance with their stated
investment objectives.
Where appropriate, the Firm also provides advice about any type of legacy position or other investment
held in client portfolios, but clients should not assume that these assets are being continuously monitored
or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage TPW to manage
and/or advise on certain investment products that are not maintained at their primary custodian, such as
variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and
qualified tuition plans (i.e., 529 plans). In these situations, TPW directs or recommends the allocation of
client assets among the various investment options available with the product. These assets are generally
maintained at the underwriting insurance company or the custodian designated by the product’s provider.
TPW tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a
continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives.
TPW consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time
horizon, liquidity constraints and other related factors relevant to the management of their portfolios.
Clients are advised to promptly notify TPW if there are changes in their financial situation or if they wish
to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions
or mandates on the management of their accounts if TPW determines, in its sole discretion, the conditions
would not materially impact the performance of a management strategy or prove overly burdensome to the
Firm’s management efforts.
Retirement Plan Consulting Services
TPW provides various consulting services to qualified employee benefit plans and their fiduciaries. This
suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing
their corporate retirement plans. Each engagement is individually negotiated and customized, and includes
any or all of the following services:
• Plan Design and Strategy • Plan Review and Evaluation
• Executive Planning & Benefits
• Investment Selection
• Plan Fee and Cost Analysis
• Plan Committee Consultation
• Fiduciary and Compliance
• Participant Education
While each of these services is available on a stand-alone basis, certain of them can also be rendered in
conjunction with investment portfolio management as part of a comprehensive wealth management
engagement (described in more detail below).
As disclosed in the Advisory Agreement, certain of the foregoing services are provided by TPW
as a
fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In
accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of
TPW’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the
Firm reasonably expects under the engagement.
Use of Independent Managers
As mentioned above, TPW selects certain Independent Managers to actively manage a portion of its clients’
assets. The specific terms and conditions under which a client engages an Independent Manager are set
forth in a separate written agreement with the designated Independent Manager. That agreement can be
between the Firm and the Independent Manager (often called a subadvisor) or the client and the Independent
Manager (sometimes called a separate account manager). In addition to this brochure, clients will typically
also receive the written disclosure documents of the respective Independent Managers engaged to manage
their assets.
TPW evaluates a variety of information about Independent Managers, which includes 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, the Firm seeks to assess the
Independent Managers’ investment strategies, past performance and risk results in relation to its clients’
individual portfolio allocations and risk exposure. TPW also takes into consideration each Independent
Manager’s management style, returns, reputation, financial strength, reporting, pricing and research
capabilities, among other factors.
TPW continues to provide services relative to the discretionary selection of the Independent Managers. On
an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent
Managers. TPW seeks to ensure the Independent Managers’ strategies and target allocations remain aligned
with its clients’ investment objectives and overall best interests.
Use of Dynasty TAMP
TPW has entered into a contractual relationship with Dynasty Financial Partners, LLC (“Dynasty”), which
provides the Firm with operational and back-office support including access to a network of service
providers. Through the Dynasty network of service providers, TPW may receive preferred pricing on
trading technology, reporting, custody, brokerage, compliance and other related services.
In addition, Dynasty’s subsidiary, Dynasty Wealth Management, LLC (“DWM”), an SEC registered
investment adviser, provides access to a range of investment services including: separately managed
accounts (“SMA”), mutual fund and ETF asset allocation strategies, and unified managed accounts
(“UMA” and together with the SMAs is the same as the Independent Managers) managed by external third
party managers (collectively, the “Investment Programs”). TPW may separately engage the services of
Dynasty and/or its subsidiaries to access the Investment Programs. Under the SMA and UMA programs,
TPW will maintain the ability to select the specific, underlying Independent Managers that will, in turn,
have day-to-day discretionary trading authority over the requisite client assets.
Dynasty charges a “Platform Fee,” for which, unless otherwise disclosed, the client will be charged,
separate from and in addition to such client’s annual investment management fee, as described in Item 5
below. This arrangement presents a conflict of interest because TPW is incentivized to allocate client
investment assets to the Investment Programs in order to receive more advantageous pricing from Dynasty.
The annual investment management fee charged to the client is not affected if Platform Fees are decreased.
TPW seeks at all times to ensure that any conflicts are addressed on a fully-disclosed basis and investment
decisions are handled in a manner that is aligned with the client’s best interests. The Firm does not receive
any portion of the fees paid directly to Dynasty or the service providers made available through its platform.
Dynasty and DWM offer an investment management platform (the “Platform” or the “TAMP") that is
available to the advisers in the Dynasty Network, such as TPW. Through the Platform, DWM and Dynasty
collectively provide certain technology, administrative, operations and advisory support services that allow
advisers to manage their own portfolios and access Independent Managers. TPW can allocate all or a portion
of client assets among the different Independent Managers via the Platform. TPW can also use the model
and/or overlay management feature of the TAMP by creating its own asset allocation model and underlying
investments that comprise the model. Through the model management feature, the Firm can outsource the
implementation of trade orders and periodic rebalancing of the model when needed.
TPW will maintain the direct contractual relationship with each client and obtain, through such agreements,
the authority to engage the Independent Managers, DWM and/or Dynasty, as applicable, for services
rendered through the Platform in service of such client. TPW may delegate discretionary trading authority
to DWM and/or Independent Managers to affect investment and reinvestment of client assets with the
ability to buy, sell or otherwise affect investment transactions and allocate client assets. If a client is
participating in certain Investment Programs, DWM or the designated Independent Manager, as applicable,
is also authorized without prior consultation of TPW or the client to buy, sell, trade or allocate such client’s
assets in accordance with the client’s designated portfolio and to deliver instructions to the designated
broker-dealer and/or custodian of such client’s assets.
In providing investment advice and portfolio management services to clients, the Firm acts as an investment
adviser and fiduciary to and on behalf of each client and not as an agent of Dynasty or DWM.