Introduction:
In this brochure, references to “we,” “us,” “our,” or “our firm” refer to TFO Wealth Partners. Individuals
who serve as our directors, officers, employees, and investment adviser representatives are referred to
as our “Supervised Persons,” “associated persons,” or “representatives.” Our firm’s clients and
prospective clients are referred to as “you,” “your,” or “our clients.”
We offer discretionary and nondiscretionary investment management services, family office services,
retirement plan services, consulting services, digital investment management services, and third-party
investment managers. Prior to engaging us to provide services, we will require you to enter a written
agreement with us setting forth the terms and conditions under which we will provide our services. Our
specific services, terms of our compensation, method of payment, and other important information are
explained in more detail below.
TFO Wealth Partners has been providing advisory services since 2003. Previous names of the entity
have been TFO-TDC, LLC, TDC St. Louis, LLC, and Husch Family Office, LLC. TFO Wealth Partners is
headquartered in Maumee, Ohio.
TFO Wealth Partners is owned by TFO Partners, Inc. and the Chief Executive Officer of TFO Wealth
Partners is Mr. Christopher Erblich.
As of December 31, 2023, TFO Wealth Partners managed $3,906,784,008 on a discretionary basis and
$25,712,218 on a non-discretionary basis for a total of $3,932,496,226 in regulatory assets under
management. In addition, TFO Wealth Partners provided retirement plan consulting services to
$721,759,128 of self-directed retirement accounts. In total, as of December 31, 2023, TFO Wealth
Partners provided investment advice to $4,654,255,354 in client assets.
Investment Management Services:
TFO Wealth Partners manages investment portfolios for a wide variety of Clients, including individuals,
high net worth individuals, family offices, qualified retirement plans, trusts, charitable organizations, small
businesses, and corporations. TFO Wealth Partners will work with a Client to determine the Client's
investment objectives and investor risk profile and will design a written investment policy statement. TFO
Wealth Partners uses investment and portfolio allocation software to evaluate alternative portfolio
designs. TFO Wealth Partners evaluates the Client's existing investments with respect to the Client's
investment policy statement. TFO Wealth Partners works with new Clients to develop a plan to transition
from the Client's existing portfolio to the desired portfolio. TFO Wealth Partners will then regularly
monitor the Client's portfolio holdings and the overall asset allocation strategy and hold review meetings
with the Client regarding the account as necessary.
TFO Wealth Partners will typically create a portfolio which may be based on one or more model portfolios
if the models match the Client's investment policy. TFO Wealth Partners will allocate the Client's assets
among various investments taking into consideration the overall management style selected by the
Client. TFO Wealth Partners primarily creates portfolios consisting of mutual funds, fixed income
securities and exchange traded funds. TFO Wealth Partners primarily recommends mutual funds offered
by Dimensional Fund Advisors (DFA) and Vanguard. DFA sponsored mutual funds follow a passive
asset class investment philosophy with low operating expenses, low holdings turnover, and below-
average capital gains distributions. DFA mutual funds generally are available for investment only by
Clients of certain authorized registered investment advisers, and all investments are subject to the
approval of the adviser. This means that you will generally not be able to make additional investments in
DFA mutual funds if you terminate your agreement with TFO Wealth Partners, except through another
adviser authorized by DFA. Client portfolios may also include some individual equity securities in
situations where disposition of these securities would present an overriding tax implication or the Client
specifically requests they be purchased and/or retained for a personal reason. These situations will be
specifically identified in the Client's Investment Policy Statement (IPS) and may be designated as non-
managed assets in certain cases.
TFO Wealth Partners manages portfolios on a discretionary basis, and in limited cases, on a non-
discretionary basis, according to the investment advisory agreement and investment policy statement
selected by the Client. A Client may impose any reasonable restrictions on TFO Wealth Partners’
discretionary authority, including restrictions on the types of securities in which TFO Wealth Partners
may invest Client's assets and on specific securities, which the Client may believe to be appropriate.
In certain circumstances, including but not limited to, for fixed income portfolio management, TFO Wealth
Partners will allocate a portion of a portfolio to an independent third-party investment adviser
("independent manager”) to manage a Client’s assets on a discretionary basis-based upon individual
Client circumstances and objectives, including, but not limited to, Client account size, tax circumstances
and type of investments. In other instances, TFO Wealth Partners and a client may enter into a tri-party
agreement with one or more independent managers for the management of certain securities or
strategies.
TFO Wealth Partners will monitor the performance of the selected independent manager(s). If TFO
Wealth Partners determines that a particular selected independent manager is not providing sufficient
management services to the Client or is not managing the Client's portfolio in a manner consistent with
the Client's personal investment guidelines or asset allocation, TFO Wealth Partners will remove the
Client's assets from that selected independent manager and may place the Client's assets with another
independent manager at TFO Wealth Partners’ discretion (for discretionary accounts). Clients may be
required to execute documents to re-allocate assets amongst independent managers. For non-
discretionary accounts, TFO Wealth Partners will make recommendations to the Client, as deemed
appropriate. Clients that determine to engage TFO Wealth Partners on a non-discretionary investment
advisory basis must be willing to accept that TFO Wealth Partners cannot affect any account
transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event
that TFO Wealth Partners would like to make a transaction for a client’s account, and client is
unavailable, TFO Wealth Partners will be unable to affect the account transaction (as it would for its
discretionary clients) without first obtaining the client’s consent.
On an ongoing basis, TFO Wealth Partners will answer Clients' inquiries regarding their accounts and
review periodically with Clients the performance of their accounts. TFO Wealth Partners will periodically
review Clients' investment policy, risk profile and discuss the re-balancing of each Client's accounts to
the extent appropriate. TFO Wealth Partners will provide to independent managers any updated Client
financial information or account restrictions necessary for the independent manager to provide advisory
services.
In addition to managing the Client's investment portfolio, TFO Wealth Partners may provide additional
wealth management services to Clients based on their unique circumstances and needs. Such services
may include consulting with Clients on various financial areas including income and estate tax planning,
business sale structures, college financial planning, retirement planning, insurance and risk management
analysis, personal cash flow analysis, establishment and design of retirement plans and trust designs,
among other things. TFO Wealth Partners also has access to a suite of various digital powered financial
planning technology solutions and provides these services to certain clients based on their
circumstances and needs.
For most clients, TFO Wealth Partners agrees to review the adequacy of current life insurance, long-term
care and disability coverage, determine future needs, and develop an appropriate insurance strategy. From
time to time, we may refer a client to an affiliate of TFO Wealth Partners for developing or implementing an
insurance strategy. Please see Item 10 – Other Financial Industry Activities and Affiliations for more
information regarding these referrals, including a discussion of conflicts of interest related to these referrals.
Clients have no obligation to purchase an insurance product through a TFO Wealth Partners adviser or any
affiliate of TFO Wealth Partners.
Upon client request and in our sole discretion, TFO Wealth Partners may provide advice with respect to
your retirement plan assets. If we determine to do so, we will make recommendations based on the
investment options available as part of your retirement plan. You are responsible for making all
transactions. We will not receive any communications from the plan sponsor or custodian, and it remains
your obligation to notify us of any changes in investment choices or restrictions pertaining to your
retirement account or plan. Unless expressly indicated by the TFO Wealth Partners to the contrary these
clients’ 401(k) plan assets shall be included as assets under management for purposes of TFO Wealth
Partners calculating its advisory fee.
Family Office Services:
In addition to investment management services described above, TFO Wealth Partners may also provide
Family Office services to select Clients. These services may include some or all of the following:
suggesting and maintaining an appropriate asset allocation, evaluation of overall financial situation and
investment portfolio, private & alternative investment analysis, coordination among advisers designated
by the Client (legal, estate, tax, accounting, insurance and banking), providing administrative support to
assist Clients with their financial matters, coordination of cash management services, advice and
reporting requested by the Client. Family Office services may not be offered to all TFO Wealth Partners
Clients.
Retirement Plan Services:
TFO Wealth Partners also provides advisory services to retirement plans. TFO Wealth Partners’ services
include, but may not be limited to, one or more of the following: analysis of the plan's current investment
platform, assisting the plan in creating an investment policy statement defining the types of investments
to be offered and the restrictions that may be imposed, recommending and periodically reviewing the
plan's investment options, constructing model portfolios, discretionary investment management,
coordinating with the plan's service providers to implement investment strategies, participant education
and performance monitoring. In certain circumstances, TFO Wealth Partners provides discretionary
services where it will select and replace the plan's investment options as necessary.
The services are designed to assist plan sponsors in meeting their management and fiduciary obligations
to Participants under the Employee Retirement Income Securities Act (“ERISA”). Pursuant to adopted
regulations of the U.S. Department of Labor under ERISA Section 408(b)(2), 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 may include some or all of those described above and will be
outlined in the service agreement with our firm. Our compensation for these services is described below,
at Item 5, and in the service agreement. We may, with consent of the Plan, and in accordance with Plan
documents, bill out of pocket expenses (such as overnight mailings, messenger, translation fees, etc.) at
cost. We do not reasonably expect to receive any other compensation, direct or indirect, for the services
we provide to the Plan or Participants.
In providing services to the Plan and Participants, our status is that of an investment adviser registered
under the Investment Advisers Act of 1940, and we are not subject to any disqualifications under Section
411 of ERISA. In performing ERISA fiduciary services, we represent that we are a fiduciary as defined in
Section 3(21) of ERISA. We may also act as a discretionary "investment manager" of the Plan as defined
in Section 3(38) under ERISA.
Consulting Services:
Clients can also receive investment advice on a more limited basis. This may include advice on an
isolated area(s) of concern such as estate planning, retirement planning, reviewing a Client's existing
portfolio, or any other specific topic. TFO Wealth Partners also provides specific consultation and
administrative services regarding investment and financial concerns of the Client. Dependent on the type
of consulting services provided, there will be a conflict of interest due to the potential for the
recommendation of our Firm to provide additional services, such as investment advisory services or
retirement plan services.
Additionally, TFO Wealth Partners provides advice on non-securities matters. Generally, this is in
connection with the rendering of estate planning, insurance, and/or annuity advice. TFO Wealth Partners
does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be
construed as same. Accordingly, TFO Wealth Partners does not prepare legal documents, prepare tax
returns, or sell insurance products. To the extent requested by a client, we may recommend the services
of other professionals for non-investment implementation purpose (i.e., attorneys, accountants,
insurance, etc.). The client is not under any obligation to engage any such professional(s). The client
retains absolute discretion over all such implementation decisions and is free to accept or reject any
recommendation from TFO Wealth Partners and/or its representatives. If the client engages any
professional (i.e., attorney, accountant, insurance agent, etc.), recommended or otherwise, and a dispute
arises thereafter relative to such engagement, the engaged professional shall remain exclusively
responsible for resolving any such dispute with the client. At all times, the engaged licensed
professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not TFO Wealth Partners, shall be
responsible for the quality and competency of the services provided.
TFO Now - Discretionary Digital Investment Advisory Platform:
1. Overview
Clients and prospective clients may determine to engage TFO Wealth Partners to provide them with
portfolio management services through TFO Now, an automated investment program. Clients are investing
in a range of investment strategies that TFO Wealth Partners has constructed and continues to manage.
Each of these portfolios may consist of mutual funds or ETFs and a cash allocation. The client may instruct
TFO Wealth Partners to exclude up to three investment positions from their portfolio. The client’s portfolio is
held in a brokerage account opened by the client at Charles Schwab & Co. (“CS&Co”). TFO Wealth
Partners uses the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance
Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co.,
to operate TFO Now. TFO Wealth Partners is independent of and not owned by, affiliated with, or
sponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). TFO Wealth Partners,
and not Schwab, is the client’s investment adviser and primary point of contact with respect to TFO Now.
As between TFO Wealth Partners and Schwab, TFO Wealth Partners is solely responsible, and Schwab is
not responsible, for determining the appropriateness of TFO Now for the client, choosing a suitable
investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio
on an ongoing basis. TFO Wealth Partners has contracted with SPT to provide it with the Platform, which
consists of technology and related trading and account management services for TFO Now. The Platform
enables TFO Wealth Partners to make TFO Now available to clients online and includes a system that
automates certain key parts of our investment process (the “System”).
The System includes an online questionnaire that helps TFO Wealth Partners determine the client’s
investment objectives and risk tolerance and select an appropriate investment strategy and portfolio.
Generally new clients will submit data on the System regarding the Client’s risk preferences, investment
objectives, and account size. Clients will also be assigned a team of representatives to their account.
For existing client's transitioning to TFO Now, the personal representative team will review and confirm
the client's investment objectives and risk tolerance during the transition process. It is the Client's
responsibility to promptly update their account application through the web-based portal or by contacting
the Client's personal representative team if there are ever any changes in the Client's financial situation
or investment
objectives for the purpose of reallocating and/or re-balancing the Client's account. Clients
should note that TFO Wealth Partners will recommend a portfolio via the System in response to the
client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is
one level less or more, conservative, or aggressive, than the recommended portfolio and the client
makes the final decision and selects their portfolio, subject to TFO Wealth Partners’ review and approval.
In limited instances, TFO Wealth Partners may agree to allow a client to invest in a portfolio that is more
conservative or aggressive by working with their personal representative team. In such cases, an
additional Investment Policy Statement will be required.
The System also includes an automated investment engine through which TFO Wealth Partners
manages the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss
harvesting (if the client is eligible and elects). TFO Wealth Partners reserves the right to override the
automatic rebalancing and tax-loss harvesting features, in which case, TFO Wealth Partners will notify
clients. TFO Wealth Partners will likely only override these features if market conditions become highly
unusual.
TFO Wealth Partners charges clients a fee for its services as described below under Item 5, Fees and
Compensation. TFO Wealth Partners’ fees are not set or supervised by Schwab. Clients do not pay
brokerage commissions or any other fees to CS&Co. as part of TFO Now. Schwab receives other
revenues in connection with TFO Now, which are described below under Item 5, Fees and
Compensation.
Clients enrolled in TFO Now are limited in the universe of investment options available to them, in that
TFO Wealth Partners currently only uses mutual funds and ETFs in TFO Now. In addition, TFO Now has
been designed for clients with generally less than $750,000, although TFO Now is available to all of our
clients who may benefit from this type of platform. Clients enrolled exclusively in TFO Now may receive
less formal wealth management services than our other clients. However, where a client had a
relationship with TFO Wealth Partners prior to offering TFO Now, the client will continue to receive the
same level of service. TFO Wealth Partners’ fee may be higher (or lower) than those charged by other
investment advisers offering similar services.
2. Rebalancing
The System will rebalance a client’s account periodically by generating instructions to CS&Co to buy and
sell shares of securities and depositing or withdrawing funds through the “Sweep Program”, considering
the asset allocation for the client’s investment strategy. Rebalancing trade instructions can be generated
by the System when (i) the percentage allocation of a security varies by a set parameter established by
TFO Wealth Partners, (ii) TFO Wealth Partners decides to change the securities or their percentage
allocations for an investment strategy or (iii) TFO Wealth Partners decides to change a client’s
investment strategy, which could occur, for example, when a client makes changes to their investment
profile or imposes or modifies restrictions on the management of their account. Accounts below $5,000
may deviate farther than the set parameters as well as the target allocation of the selected investment
profile. Rebalancing below $5,000 may impact the ability to maintain positions in selected asset classes
due to the inability to buy or sell in smaller quantities. For example, withdrawal requests may require
entire asset classes to be liquidated to generate and disburse the requested cash.
3. Sweep Program
Each investment strategy involves a cash allocation (“Cash Allocation”) that will be held in a sweep
program at Charles Schwab Bank (the “Sweep Program”). The Cash Allocation will be a minimum of 4%
of an account’s value to be held in cash, and may be higher, depending on the investment strategy
chosen for a client. The Cash Allocation will be accomplished through enrollment in the Sweep Program,
a program sponsored by CS&Co. By enrolling in TFO Now, clients consent to having the free credit
balances in their brokerage accounts at CS&Co swept into deposit accounts (“Deposit Accounts”) at
Charles Schwab Bank (“Schwab Bank”) through the Sweep Program. Schwab Bank is an FDIC-insured
depository institution that is a Schwab affiliate. The Sweep Program is a required feature of TFO Now. If
the Deposit Account balances exceed the Cash Allocation for a client’s investment strategy, the excess
over the rebalancing parameter will be used to purchase securities as part of rebalancing. If clients
request cash withdrawals from their accounts, this likely will require the sale of securities in their
accounts to bring their Cash Allocation in line with the target allocation for their chosen investment
strategy. If those clients have taxable accounts, those sales may generate capital gains (or losses) for
tax purposes. In accordance with an agreement with CS&Co, Schwab Bank has agreed to pay an
interest rate to depositors participating in the Sweep Program that will be determined by reference to an
index.
Miscellaneous Disclosures Regarding Our Services:
1. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services.
To the extent specifically requested, TFO Wealth Partners will generally provide planning and consulting
services regarding non-investment related matters, such as tax, estate and insurance planning. We may
agree to include these services in our fee referenced in Item 5 below or may discuss charging you an
additional fee under a separate agreement depending on the nature of the engagement, amount of your
assets under management, and the complexity of your planning needs. TFO Wealth Partners does not
serve as an attorney, accountant, or insurance agency, and no portion of our services should be
construed as legal, accounting or insurance advice requiring licensing. TFO Wealth Partners does not
prepare legal documents, tax returns, or sell insurance products. To the extent requested by a client, we
will recommend the services of other professionals for certain non-investment implementation purpose
(i.e., attorneys, accountants, insurance agencies or agents). Some of these parties may be
representatives or affiliates of TFO Wealth Partners in their separate individual capacities as licensed
insurance agents, certified public accountants and attorneys. You should review Item 10 below for
additional information. You are under no obligation to engage the services of any recommended
professional. You retain absolute discretion over all implementation decisions and are free to accept or
reject any recommendation from TFO Wealth Partners or its representatives. If you engage any
recommended unaffiliated professional, and a dispute arises, the engaged professional shall remain
exclusively responsible for resolving any such dispute with the client. The recommendation by a TFO
Wealth Partners representative that a client purchase an insurance product, presents a conflict of
interest, as the receipt of commissions provides an incentive to recommend investment products based
on commissions to be received, rather than on a particular client’s need. No client is under any obligation
to purchase any insurance products from a TFO Wealth Partners representative or engage any
representative in any other professional capacity. Clients are reminded that they are free to purchase
insurance products, accounting, legal or other services through other, non-affiliated parties. TFO Wealth
Partners’ Chief Compliance Officer, Brady Fineske, remains available to address any questions that a
client or prospective client may have regarding the above conflicts of interest.
2. Other Assets. A client may:
• hold securities that were purchased at the request of the client or acquired prior to the client’s
engagement of TFO Wealth Partners. Generally, with potential exceptions, TFO Wealth Partners
does not/would not recommend nor follow such securities, and absent mitigating tax
consequences or client direction to the contrary, would prefer to liquidate
such securities. Please Note: If/when liquidated, it should not be assumed that the replacement
securities purchased by TFO Wealth will outperform the liquidated positions. To the contrary,
different types of investments involve varying degrees of risk, and there can be no assurance that
future performance of any specific investment or investment strategy (including the investments
and/or investment strategies recommended or undertaken by TFO Wealth) will be profitable or
equal any specific performance level(s)In addition, there may be other securities and/or accounts
owned by the client for which the Registrant does not maintain custodian access and/or trading
authority; and,
• hold other securities and/or own accounts for which TFO Wealth does not maintain custodian
access and/or trading authority.
Corresponding Services/Fees: When agreed to by TFO Wealth, TFO Wealth shall: (1) remain
available to discuss these securities/accounts on an ongoing basis at the request of the client; (2)
monitor these securities/accounts on a regular basis, including, where applicable, rebalancing with
client consent;(3) shall generally consider these securities as part of the client’s overall asset
allocation; and, (4) report on such securities/accounts as part of regular reports that may be provided
by TFO Wealth; and, (5) include the market value of all such securities for purposes of
calculating advisory fee.
3. Third-Party Investment Managers. TFO Wealth Partners may use or recommend using unaffiliated
third-party investment managers to manage all or a portion of a client’s account in accordance with the
client’s designated investment objective(s). Most notably, we may rely on third-party investment
managers to manage fixed income portfolios for client accounts and may use them to gain exposure to
other investment strategies. The third-party manager is responsible for the discretionary management of
the allocated assets. Factors that TFO Wealth Partners shall consider in recommending third-party
investment manager[s] include the client’s designated investment objective(s), management style,
performance, reputation, financial strength, reporting, pricing, and research. We will continue to
supervise the third-party manager and provide ongoing monitoring and review of your account
performance, asset allocation and investment objectives. The fee charged by the third-party manager is
in addition to our advisory fee discussed in Item 5 below.
4. Margin Accounts. A Client who has a need to borrow money could determine to do so by using
margin. Each Client must sign a separate margin agreement before margin is extended to that Client
account. Fees for advice and execution on these securities are based on the total asset value of the
account, which includes the value of any securities purchased on margin. The use of margin will also
result in interest charges, assessed by and paid to the custodian, pursuant to the custodial agreement, in
addition to all other fees and expenses associated with the security involved. The use of margin may
allow for more favorable interest rates than standard commercial loans. These types of collateralized
loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable
borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However,
such loans are not without potential material risk to the client’s investment assets. The lender (i.e.,
custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan
default or if the assets fall below a certain level. For this reason, TFO Wealth Partners does not
recommend such borrowing unless it is for specific short-term purposes (i.e., a bridge loan to purchase a
new residence). TFO Wealth Partners does not recommend such borrowing for investment purposes
(i.e., to invest borrowed funds in the market). Regardless, if the client was to determine to utilize margin
or a pledged assets loan, the following economic benefits would inure to TFO Wealth Partners:
• by taking the loan rather than liquidating assets in the client’s account, TFO Wealth
Partners continues to earn a fee on such Account assets; and,
• if the client invests any portion of the loan proceeds in an account to be managed by TFO
Wealth Partners, TFO Wealth Partners will receive an advisory fee on the invested amount;
and,
• if TFO Wealth Partners’ advisory fee is based upon the higher margined account value,
TFO Wealth Partners will earn a correspondingly higher advisory fee. This could provide
TFO Wealth Partners with a disincentive to encourage the client to discontinue the use of
margin.
Please Note: The Client must accept the above risks and potential corresponding consequences
associated with the use of margin or a pledged assets loan.
5. Reporting Services. TFO Wealth Partners can also provide account reporting services, which can
incorporate client investment assets that are not part of the assets that TFO Wealth Partners manages
(the “Excluded Assets”). Unless agreed to otherwise, in writing, the client and/or his/her/its other
advisors that maintain trading authority, and not TFO Wealth Partners, shall be exclusively
responsible for the investment performance of the Excluded Assets. Unless also agreed to
otherwise, TFO Wealth Partners does not provide investment management, monitoring, or
implementation services for the Excluded Assets. If TFO Wealth Partners is asked to make a
recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the
recommendation, and TFO Wealth Partners shall not be responsible for any implementation error
(timing, trading, etc.) relative to the Excluded Assets. The client can engage TFO Wealth Partners to
provide investment management services for the Excluded Assets pursuant to the terms and conditions
of the Investment Advisory Agreement between TFO Wealth Partners and the client.
• In the event that TFO Wealth provides the client with access to an unaffiliated vendor’s website
such as emoney or ByAllAccounts, and the site provides access to information and/or concepts,
including financial planning, the client, should not, in any manner whatsoever, infer that such
access is a substitute for services provided by TFO Wealth. Rather, if the client utilizes any such
content, the client does so separate and independent of TFO Wealth.
6. Cybersecurity Risk. The information technology systems and networks that TFO Wealth Partners
and its third-party service providers use to provide services to TFO Wealth Partners’ clients employ
various controls, which are designed to prevent cybersecurity incidents stemming from intentional or
unintentional actions that could cause significant interruptions in TFO Wealth Partners’ operations and
result in the unauthorized acquisition or use of clients’ confidential or non-public personal information.
Clients and TFO Wealth Partners are nonetheless subject to the risk of cybersecurity incidents that could
ultimately cause them to incur losses, including for example: financial losses, cost and reputational
damage to respond to regulatory obligations, other costs associated with corrective measures, and loss
from damage or interruption to systems. Although TFO Wealth Partners has established its systems to
reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts
will always be successful, especially considering that TFO Wealth Partners does not directly control the
cybersecurity measures and policies employed by third-party service providers. Clients could incur
similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of
securities in which those clients invest, broker-dealers, qualified custodians, governmental and other
regulatory authorities, exchange and other financial market operators, or other financial institutions.
7. Client Obligations. In performing our services, we are not required verify any information received
from you or your other professionals and is expressly authorized to rely on the information we receive. It
remains your responsibility to promptly notify us if there is ever any change in your financial situation or
investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations
and/or services.
8. Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it
should not be assumed that future performance of any specific investment or investment strategy (including
the investments and/or investment strategies recommended or undertaken by TFO Wealth Partners) will
be profitable or equal any specific performance level(s).
9. Disclosure Statement. A copy of the TFO Wealth Partners’ written Privacy Notice, Disclosure
Brochure as set forth on Part 2 of Form ADV and Form CRS (Client Relationship Summary) shall be
provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory
Agreement or Financial Planning Agreement.