TFG Financial Advisors LLC (hereinafter “TFG Financial”) is a registered investment advisor based in North Palm
Beach, Florida. We are a limited liability company, organized under the laws of the State of Florida. We have been
providing investment advisory services since 2017. The Fuoco Group Holding, LLC is the principal owner of TFG
Financial. Luigi Fuoco is the sole owner of The Fuoco Group Holding, LLC.
You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to
anyone from our firm who is an officer, an employee, and all individuals providing investment advice on behalf of
our firm. Where required, such persons are properly registered as investment adviser representatives.
Currently, we offer the following investment advisory services, personalized for each individual Client:
• Financial Planning Services
• Portfolio Management Services
• Selection of Third Party Investment Advisers
• Pension Consulting Services
Financial Planning Services
TFG Financial offers various financial planning related services, which assist Clients in the management of their
financial resources. Financial planning services are based upon an analysis of the Client’s individual needs
beginning with one or more information gathering consultations. Once the firm has collected and analysed all
documentation gathered during these consultations, TFG Financial provides a written financial plan designed to
achieve the Client’s financial goals and objectives. TFG Financial then assists Clients 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 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; and, to coordinate and
organize records and estate information.
• Retirement Analysis – Identification of 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 your needs, e.g., life, health, disability, and long-term care
insurance. This will necessitate an analysis of cash needs of the Client’s family at death, income needs of
surviving dependents, and potential disability income needs.
• Portfolio Analysis/Investment Planning – Presentation of investment alternatives, including asset
allocation and its effect on the Client’s portfolio; evaluation of economic and tax characteristics of
existing investments as well as their suitability for the Client; and, identification and evaluation of 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 – Advising Clients 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 revisions to meet changing circumstances. Financial plans are
based on your financial situation based on the information provided to the firm. We should be notified promptly
of any change to your financial situation, goals, objectives, or needs.
Portfolio Management Services
Our firm offers discretionary and non-discretionary portfolio management services to our Clients. Discretionary
portfolio management means we will make investment decisions and place buy or sell orders in your account
without contacting you. These decisions would be made based upon your stated investment objectives. If you
wish, you may limit our discretionary authority by, for example, setting a limit on the type of securities that can
be purchased for your account. Simply provide us with your restrictions or guidelines in writing. If you have
engaged us for non-discretionary portfolio management services, we will obtain your approval prior to executing
all transactions in your account(s).
Our investment advice is tailored to meet our Clients’ needs and investment objectives. If you decide to hire our
firm to manage your portfolio, we will meet with you to gather your financial information, determine your goals,
and help you decide how much risk you should take in your investments. The information we gather will help us
implement an asset allocation strategy that will be specific to your goals, whether we are actively investing for
you or simply providing you with advice.
TFG Financial does not specialize in specific types of securities. We can advise Clients on various types of securities,
such as exchange listed equities, over the counter equities, foreign issues, American depository receipts,
corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company
securities (including mutual funds and exchange traded funds), US Government securities, options contracts on
securities and/or commodities, private equity instruments, and interests in partnership investing in real estate.
Additionally, will provide advice on existing investments you may hold at the inception of the advisory relationship
or on other types of investments for which you ask advice.
If you engage us for portfolio management services, we will monitor your portfolio’s performance on a continuous
basis, and rebalance the portfolio whenever necessary, as changes occur in market conditions and/or your
financial circumstances.
Recommendation of Sub Advisors
As part of our overall portfolio management strategy, we may recommend sub advisers to manage all or a portion
of your account. All sub advisers recommended by our firm must either be registered as investment advisers or
exempt from registration requirements. These sub advisers may specialize in traditional or alternative
investments. Factors that we take into consideration when making our recommendations include, but are not
limited to, the following: the sub adviser’s performance, methods of analysis, fees, your financial needs,
investment goals, risk tolerance, and investment objectives. Once a sub advisory account has been established,
we will provide all administrative and clerical duties that are required to service your account. The sub adviser
will have little or no direct contact with you. Our responsibility to you will be to: (i) continuously evaluate the
performance of your portfolio to ensure the sub adviser selected adheres to your asset allocation guidelines; (ii)
make recommendations regarding the sub adviser as market factors and your personal goals dictate, (iii) assume
discretionary authority to hire or fire the sub adviser where such action is deemed to be in your best interest.
Selection of Third-Party Investment Advisers
TFG Financial has entered into agreements with various third-party investment advisers for the provision of
certain investment advisory services. Factors considered in the selection of a third-party advisor include but may
not be limited to: i) TFG Financial’s preference for a particular third-party advisor; ii) the client’s risk tolerance,
goals and objectives, as well as investment experience; and, iii) the amount of client assets available for
investment.
In order to assist clients in the selection of a third-party advisor, an Associated Person of TFG Financial
will typically gather information from the client about the client’s financial situation, investment objectives, and
reasonable restrictions the client wants imposed on the management of the account.
The third-party advisor may customize the client's portfolio by blending traditional investment strategies with an
allocation to asset classes. The investment strategy adopted by the third-party advisor may embrace value,
growth, or contrarian investing styles. Generally, securities transactions will be decided upon and executed by the
third-party advisor on a discretionary basis. This means that the manager selected will have the ability to buy and
sell securities in your account without obtaining your approval. TFG Financial and its Associated Persons will not
manage, or obtain discretionary authority over the assets in accounts participating in these programs; however,
clients may grant TFG Financial the discretionary authority to hire and fire such third party managers. Generally,
clients may not impose restrictions on investing in certain securities or types of securities in accounts managed
by a third-party advisor.
Associated Persons of TFG Financial will periodically review reports provided to the client. An Associated Person
of TFG Financial will contact the client at least annually, or more often as agreed upon with each client, to review
the client’s financial situation and objectives, communicate information to the third-party advisor managing the
account as necessary, and to assist the client in understanding and evaluating the services provided by the third-
party advisor. Clients will be expected to notify TFG Financial of any changes in their financial situation, investment
objectives, or account restrictions.
The third-party advisor may offer wrapped or non-wrapped pricing options. Wrap pricing structures allow the
client to pay an all-inclusive fee for management, brokerage, clearance, custody, and administrative services. In
a non-wrap pricing structure, the third-party advisor’s fee may be separated from the advisory fee charged by
TFG Financial. Transaction costs may also be charged for the execution and clearance of advisory transactions
directed by such third-Party Advisory Services. A complete description of the programs and services provided, the
amount of total fees, the payment structure, termination provisions and other aspects of each program are
detailed and disclosed in: i) the third-party advisor’s Form ADV Part 2A; ii) the program wrap brochure (if
applicable) or other applicable disclosure documents; iii) the disclosure documents of the portfolio manager(s)
selected; or, iv) the third-party advisor’s account opening documents. A copy of all relevant disclosure documents
of the third-party advisor and of the individual portfolio manager(s) will be provided to anyone interested in these
programs/managers.
Pension Consulting Services
TFG Financial provides several pension consulting related services separately or in combination. While the primary
clients for these services will be pension, profit sharing and 401(k) plans, TFG Financial will also offer these
services, where appropriate, to individuals and trusts, estates and charitable organizations. Pension consulting
services are comprised of four distinct services. Clients may choose to use any or all of these services:
Investment Policy Statement Preparation
TFG Financial will meet with the client (in person or over the telephone) to determine the client's investment
needs and goals. TFG Financial will then prepare a written Investment Policy Statement (“IPS”) stating those needs
and goals and creating a policy to help achieve these goals. The IPS will also list the criteria for selection of
investment vehicles and the procedures and timing interval for monitoring of investment performance.
Selection of Investment Vehicles
TFG Financial 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 IPS. The number of investments to be recommended will be determined
by the client, based on the 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 TFG Financial will not be involved in any way in the purchase or sale of
these investments, TFG Financial 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''), TFG Financial also provides educational support and
investment workshops designed for the Plan participants. The nature of the topics to be covered will be
determined by TFG Financial 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.
These services are designed to assist plan sponsors in meeting their management and fiduciary obligations to
Participants under ERISA. Pursuant to adopted regulations of the U.S. Department of Labor, we are required to
provide the Plan's responsible plan fiduciary (the person who has the authority to engage us as an investment
adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive
for providing those services, and our status (which is described below).
The services we provide to your Plan are described above, and in the service agreement that you have previously
signed. Our compensation for these services is described below, in Item 5, and also in the Pension Consulting
Agreement. We do not reasonably expect to receive any other compensation, direct or indirect, for the services
we provide to the Plan or Participants, unless the plan sponsor directs us to deduct our fee from the plan or directs
the plan record-keeper to issue payment for our fee out of the plan. If we receive any other compensation for
such services, we will (i) offset the compensation against our stated fees, and (ii) we will promptly disclose the
amount of such compensation, the services rendered for such compensation and the payer of such compensation
to you.
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.
TFG Financial is registered as an investment advisor and represents that it is not subject to any disqualification as
set forth in Section 411 of ERISA. To the extent TFG Financial performs Fiduciary Services, TFG Financial is acting
as a fiduciary of the Plan as defined in Section 3(21) under ERISA.
Wrap Fee Programs
We do not sponsor, manage, or participate in any wrap fee programs.
Assets Under Management
As of January 1, 2024, our firm has $110,553,201in discretionary and $1,345,906 in non-discretionary assets under
management.
Important Note: Information related to tax and legal matters that is provided as part of a financial plan is for
informative purposes only. Clients are instructed to contact their tax or legal advisers for personalized advice.