A. OUR FIRM
We are a fiduciary investment advisory firm, solely compensated by fully disclosed fees paid by our clients. In
plain terms, that means our primary objective is to operate in your best interests. It also means that we will
avoid conflicts of interest whenever possible. If a conflict of interest exists, we will clearly reveal it to you as
well as why we believe that we could not avoid that conflict. Our recommendations and management are driven
solely by our duty to act on behalf of you, our clients, as objective fiduciary managers, and advisers.
We are organized as The Wealth Coach, LLC, a limited liability company domiciled in the State of Texas, doing
business nationally. We have been operating as an investment adviser since July of 2007. Before, that name and
others were used going back to 1983 describing operations of our primary members as an independently
contracting branch office of a series of investment advisers and securities broker-dealers.
The majority owner of TPWC is Jeffrey W. McClure, CFP®. Minority ownership of the firm is held by individual
advising member, Jacob A. McClure, CIMA®, as well as the longer serving staff members at our Salado, Texas
headquarters.
B. INVESTMENT ADVISORY SERVICES OFFERED
We primarily design and manage investment portfolios for individuals, families, trusts, pensions, and
foundations. When requested, we will provide general personal financial planning, investment and/or business
advice if we believe we have the appropriate expertise in the specific area for which you have made the request.
Before we assess any fees or provide formal advice, we will provide you with an Investment Advice and Account
Management Agreement (“The Agreement”) for your review and approval. The Agreement will include schedules
of the investment accounts on which you wish advice and management, the specific fees we propose to charge,
and the specifics of how we propose to bill and collect those fees. We will also include a form as a part of The
Agreement allowing you to list any specific requirements, restrictions, or objectives you may have. We will ask
you to sign and return The Agreement before we proceed.
We do not offer generalized tax advice, but we will provide limited advice on investment tax and estate tax
planning issues. We strongly advise you to consult with a qualified tax adviser such as a Certified Public
Accountant or a board-certified tax attorney prior to authorizing or executing any tax-related transaction and
specific tax withholding amounts. In our opinion, the advice and assistance of a qualified tax professional
increases in importance as the size of your portfolio grows. If you believe that your estate is potentially at risk
because of estate tax issues, we strongly recommend you consult with a qualified estate attorney. We will be
glad to work with your attorney to structure your portfolio to minimize estate taxes.
If you have a regular tax-deferred retirement account, qualified under the Employee Retirement Income
Security Act of 1974 (ERISA), such as an Individual Retirement Account (IRA), or employer-sponsored
retirement plan managed by us, we will attempt, in concert with your tax professional, to schedule your
requested withdrawals from that account to provide you with the best tax position for any given year.
When we are managing a fully taxable investment account for you, we will attempt to take into consideration
the tax implications of investment liquidations; however, when we are faced with a potential risk to your
investment, we will prioritize investment decisions over tax management.
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We also do not offer legal advice. If we believe that a legal document you may be using is questionable, we will
outline our questions and suggestions, and advise you to consult with a qualified attorney. We strongly
encourage you to consult with a qualified attorney before taking any action with regard to your estate or any
transfer of property to or from a different status or entity.
INVESTMENT PORTFOLIO DESIGN AND MANAGEMENT
In our investment portfolio design and management, we will start with an asset allocation analysis from the
current value of your portfolio, the amount and frequency of your planned future additions and/or withdrawals,
and your perception and attitude regarding market value variance or market risk. Through our conversations
with you and the answers you provide in our Risk Tolerance Questionnaire, we will estimate the level of market
risk that we believe you may be able to tolerate and would be prudent.
As a primary philosophy, we attempt to eliminate non-systemic risk from your portfolio. That means that any
investment custodian we use or recommend will hold your investments in positions that are exempt from
creditor claims incurred by any affiliated or associated company or firm and audited regularly by a major auditing
firm.
We will base your portfolio design analysis on the tenets of Portfolio Selection, by Harry Markowitz as published
in the March 1952 edition of The Journal of Finance and for which Dr. Markowitz was awarded the Nobel Prize
in Economics in 1990. That publication outlines a theory of portfolio construction based on the concept of
using asset classes rather than individual security selection or industry emphasis as the primary foundation for
portfolio selection. This is often referred to as Modern Portfolio Theory.
Since the publishing of Dr. Markowitz’s work, numerous peer-reviewed professional journals have published
studies indicating that between 65% and 95% of the market risk and total volatility of return produced by a
broadly diversified portfolio of investments is attributable to asset allocation. In those studies, market timing,
security selection, and even minimizing cost accounted for only between 5% and 35% of the total performance.
As a result, we believe the most critical decision we will make in designing and managing your portfolio is determining the
appropriate asset allocation to meet your specified needs and objectives.
Modern Portfolio Theory states that a portfolio’s market risk will rise as the expected return rises. There is a
line of possible portfolios at given expected returns that have the least risk for their return. Dr. Markowitz
identified that line as The Efficient Frontier. Our objective will be to position your long-term investment
portfolio as close to that efficient frontier as is possible.
In the chart below, the area just below the upper-left boundary of the oval is where portfolios that carry the
least market risk for any given level of expected return sit. Inefficient portfolios will be located down and to
the right of that area. Inefficient portfolios can reasonably be expected to drop further in declining markets and
take longer to recover than would efficient portfolios. They can also be reasonably expected to rise further
during so called bubbles.
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An asset class is a set of investment securities with similar characteristics and which over time demonstrates a
distinct behavior pattern measurably different from other classes. We typically will consider twenty or more
asset classes when designing a portfolio.
For example, domestic equity (stock) asset classes may be value stocks, those that trade at a relative discount to
the underlying value of the company, or growth stocks, those which have a total market value higher than the
break-up value of the company, but which are believed to be destined for higher earnings in the future. Some
companies are not clearly definable as either value or growth but have a blend of those characteristics and are
blend stocks. A further division of domestic equity asset classes depends on size according to the companies’
capitalization or total market value. We use the three size divisions of small-capitalization, mid-capitalization, and
large-capitalization. Thus, within general domestic equities (stocks) traded in the United States, there are nine
general equity asset classes. Further subdivisions we use include Real-Estate Stocks and Natural Resources
Stocks.
Studies, and more particularly the Fama-French Three-Factor Model, published by Eugene Fama and Kenneth
French, have indicated that over the long term, value stocks tend to perform better than growth stocks and
Examples of Domestic Equity (stock) Asset Classes
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smaller-capitalization stocks tend to perform better than larger-capitalization stocks. Markowitz optimized
portfolios will rarely contain growth or blend stock asset classes except in cases where the asset class choice is
extremely limited. For those reasons it would be unusual for us to include growth or blend asset classes in your
portfolio. Because we are seeking not only a better rate of return, but also a lower overall volatility, we will
normally include mid-cap stock funds rather than large-cap or small-cap funds as a general domestic equity
asset class. Additionally, we utilize multiple asset classes in non-U.S. stocks, including Diversified Emerging
Market stocks, and Foreign Value stocks.
When dealing with debt securities, the credit quality of the issuer and the average length of time to maturity of
the underlying set of securities (among other criteria), define fixed-income asset classes. For example, we use
short, intermediate, and long-term U.S. Treasury securities, and short and intermediate-term corporate bonds
(among others) as fixed-income asset classes.
A critical point in understanding asset classes and general market behavior is that the higher the long-term
return of an asset class, the greater will be its risk over the shorter term.
The objective of Markowitz’s theory in Portfolio Selection (as we use it in your portfolio) is to create a combination
of asset classes that historically have provided the least variance or market risk needed to achieve the expected
return necessary to achieve your goals and objectives. If an asset class is currently and significantly above its
historic average long-term return, then we will reduce the maximum allocation that the Markowitz model can
assign to that class. We will additionally adjust the allocation
in fixed-income assets to reflect the average net
yield to maturity of the funds we use.
We choose the individual funds to represent the asset classes selected in your portfolio allocation according to:
• Historical management performance regarding both risk and return relative to Morningstar Category,
• Morningstar Medalist rating (if available),
• Length of management tenure,
• Consistency of return, and
• Internal cost structure.
Our primary source of information for these elements is Morningstar, Inc. We also will use other sources
including fund prospectuses, Standard and Poor’s, The Wall Street Journal, Barron’s, and other financial
publications. As a proxy for asset classes as defined by Markowitz (Portfolio Selection, 1952), we utilize
Morningstar Categories.
We use only no-load or load-waived funds unless you have a pre-existing investment or investments which
would impose penalties for liquidation prior to a maturity date or provide some benefit other than investment
value which we believe, and you agree would be in your best interest to retain.
If active management in a mutual fund or funds has not demonstrated a significant benefit in total long-term
return for an asset class then, when possible, we will use low-cost index funds to represent that asset class. If
active managers are available that have consistently demonstrated a significantly better return over time relative
to their Morningstar category, then we will select one or more actively managed funds to represent the asset
class in your portfolio. Typically, we look for that consistently superior return to have been demonstrated over
at least the last five to ten years.
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If we are managing or advising on a portfolio for you in a retirement plan, variable annuity, or some other set
of limited investment choices, we will adjust the asset allocation model to fit those asset classes and funds
available in your plan or investment product.
We will regularly and frequently review the individual funds used in your portfolio to detect changes in
management or other indications that the investment may no longer be appropriate. When we discover
information that causes us to no longer believe that the fund is likely to have a superior return into the future,
we will move your investment to what we consider to be a better selection or selections.
BUSINESS PLANNING AND ADVICE
We offer business planning and general advice to businesses and to individuals who have responsibility for the
running of a business or are considering starting a business. Fees for business planning and advice will be
negotiated in advance and agreed to in writing prior to beginning the process. Our services in this area are
limited to the following:
• Creating a business plan,
• Measuring demand for products,
• Setting prices for products,
• Business valuation, and
• Efficiency evaluation of a given product to sales ratio (Equilibrium Price).
INVESTMENT TYPES ON WHICH WE OFFER ADVICE AND MANAGEMENT
Our advice and management of securities will generally be limited to investments registered under The
Investment Company Act of 1940, recommend savings positions such as Certificates of Deposit insured by the
Federal Deposit Insurance Company (FDIC), or other federally chartered agency or individual securities backed
by the full faith and credit of the United States government like US Government bills, notes and bonds. We
have found no evidence that utilization of individual general securities (individual stocks), options, futures
contracts, or so-called “alternative” investments creates a better likelihood of increased return or reduced risk
in an investment portfolio when compared with carefully selected funds registered under that act.
At your request, if we do not consider it significantly detrimental to the performance of your portfolio, and as
a relatively small percentage of your total portfolio, we can offer specific advice concerning individual securities;
however, that advice will generally be limited to providing you with published reports and purchase or sale
advice from services to which we subscribe. In the event that you choose to hold a significant portion of your
portfolio in individual securities, we will advise you of that risk and ask you to agree in writing that you
understand the increased risk involved.
We will consider providing advice on other types of investments if we believe that we have the appropriate
expertise to do so. Those types of investments include individual bonds and other debt securities, common
stocks, partnerships, real estate, oil and gas interests, employee stock options, and the purchase or sale of a
business or a portion of a business.
We may rarely recommend variable universal life insurance, variable annuities, and/or term life insurance
contracts. We are willing to manage or advise on existing variable investment contracts you may hold. If we
determine that it is not in your best interests to continue to hold a specific insurance contract, we may
recommend a transfer to an alternative.
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We will provide our management or advice on active, employer-sponsored retirement accounts on the same
basis as we use on retirement and other accounts held at custodians we recommend, but you will be responsible
for making the changes we recommend.
If you hold a defined-contribution employer-sponsored retirement account, such as a 401(k), 403(b), SIMPLE
IRA or similar account, and you are no longer employed by that employer, we will analyze the pros and cons
of keeping it there or transferring it to an IRA at a custodian we recommend. We believe that an IRA as we
structure it normally offers less risk, greater ease of control, and in some cases, lower costs than an employer-
sponsored plan, but some employer-sponsored plans offer outstanding benefits, and we would recommend
that you retain them.
C. SERVICES TAILORED TO THE INDIVIDUAL NEEDS OF CLIENTS
We focus on designing each investment portfolio to meet your specific needs. We do not have a proprietary set
of investment portfolios or funds into which we will invest your money. In our ongoing research, we will have
a set of mutual funds in each asset class that we have determined to be preferable; however, we may utilize
funds you already hold in order to minimize taxes or other expenses that we believe may more than offset the
investment advantage of moving to a new investment.
The investments we use in your accounts may vary from those we use in other accounts. That variance may be
the result of the size of your account, the length of time you intend to hold the account, your intended use and
timing for the proceeds from the account, the continued “open” availability of the fund, and/or your individual
stated preferences.
INVESTMENT POLICY STATEMENT
We will not routinely prepare a comprehensive financial plan as defined by the Certified Financial Planner
Board of Standards. Instead, we will address the specific areas that you request, as well as other investment-
related areas that we believe might have a significant effect on your long-term standard of living or the viability
of your investment portfolio. If you wish us to prepare a formal, comprehensive financial plan for you, we may
agree to do so; however, we may charge you an additional fee for that service. If it’s anticipated that we may
charge you an additional fee, we will come to a consensus and include any changes in The Agreement for your
approval in advance.
We will prepare an Investment Policy Statement (IPS) for you and use it as the primary guide for our
management or advice on your portfolio. At a minimum your IPS will include:
• Basic information about your age and time horizon as we understand it,
• Your specific goals and objectives regarding your portfolio and your uses for it,
• An assessment of your tolerance for market risk,
• The specific accounts and their type with regard to tax treatment and restriction which you wish for
us to manage or provide advice, and
• A set of statistical information describing the hypothetical historical and expected performance of your
prior and optimized asset allocations as well as the S&P 500 Stock Index for reference.
It is critical that you carefully review this information, as we believe the historical market declines we illustrate
in your IPS are a good guide to the level of market declines you may see in the future. If you are uncomfortable
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with the degree of decline seen in the IPS illustrations, a less aggressive allocation with a lower expected return
may be more appropriate for you.
Supplemental information delivered with your IPS will include the specific investments we intend to initially
use in your portfolio. You are encouraged to review the investments using one or more of the online
information systems, e.g., Yahoo Finance, Google Finance, or Morningstar. Both the specific investments and
the asset allocation model for your portfolio will almost certainly be changed as time passes, but your initial
positioning is a good example of the way we design and manage a portfolio.
D. WRAP FEE PROGRAM
We are not the sponsors of a wrap fee program, nor do we utilize wrap fee programs. Wrap fee programs
include an arrangement whereby we would delegate the management of some of or all of your portfolio to
another investment adviser or include transaction costs and commissions charged by a custodial broker-dealer
as part of our fees. Instead, we select the securities used for your portfolio ourselves and attempt to minimize
your total expenses, including internal fund fees and transaction fees.
E. AMOUNT OF CLIENT ASSETS UNDER MANAGEMENT
As of December 31, 2023, we managed accounts on which we have discretionary trading authority for assets
totaling $187,134,683, and an approximate number on which we did not have discretionary trading authority
totaling $21,694,606 for a total combined approximate value of assets under management of $208,829,289. We
provide continuous and regular supervisory or management services on those accounts for approximately 231
clients (households or corporate/trust entities).