A. Description of Services
PrimeTRUST Advisors, LLC. ("PrimeTRUST", "Advisor" or the "Firm") is a registered investment
adviser with the U.S. Securities and Exchange Commission ("SEC"). The Advisor is based in
Greenville, South Carolina. The Firm is organized as a limited liability company under the laws of the
State of South Carolina. PrimeTRUST has been providing investment advisory services since 2006.
Julian Grice (Chip) Hunt, Jr. is the Firm's principal owner.
This Disclosure Brochure provides information regarding the qualifications, business practices, and the
advisory services provided by PrimeTRUST. The words "you", "your" and "Client", as used in this
brochure, refer to you as either a Client or prospective Client of PrimeTRUST. Also, you may see the
term "Associated Person(s)" throughout this brochure. Associated Persons are the Firm's officers,
employees, and all individuals providing investment advice on behalf of the Firm.
B. Advisory Services Offered – Institutional Clients
PrimeTRUST Advisors offers fee-based investment advisory services and consulting services to
Institutional Clients sponsoring tax-qualified defined-benefit pension and defined contribution
retirement plans (each referred to as "Retirement Plan") for their employees.
Investment Management Services
PrimeTRUST offers investment advisory services to those institutions sponsoring various types of
Retirement Plans, including defined benefit plans, cash balance pension plans, profit sharing plans,
employee stock ownership plans, 401(k) plans, and 403(b) plans. The Firm's services are designed to
guide institutional plan sponsors to support their fiduciary obligations under the Employee Retirement
Income Security Act ("ERISA").
The Firm works with Institutional Clients to establish the Retirement Plan's investment needs, goals,
and objectives. PrimeTRUST then prepares a written investment policy statement to memorialize the
goals, the investment performance standards and criteria under which the investment fund options are
to be initially selected and then measured, monitored, and evaluated on a recurring basis.
PrimeTRUST will primarily recommend mutual funds or ETFs for the Institutional Clients' Retirement
Plan according to the selection guidelines within the Investment Policy Statement.
For defined benefit pension plans, PrimeTRUST will work with the institution's duly appointed
retirement committee to establish the asset allocation that best aligns with the institution's financial
parameters including considerations such as their financial risk objectives, funded status, and desired
contribution levels.
Under the Firm's non-discretionary investment advisory services arrangement, the definitive decision-
making authority for the selection of the Retirement Plan's investment options belongs exclusively to
the Institutional Client upon consideration of the advisory services provided by the Advisor.
In addition to the non-discretionary investment advisory services, in certain circumstances,
PrimeTRUST may accept the responsibility to manage plan assets with discretion as a fiduciary. In
performing fiduciary services, the Firms is acting as a discretionary fiduciary of the Retirement Plan as
defined in Section 3(38) under ERISA. In these cases, the terms and conditions for such an
engagement are included in the investment advisory services agreement.
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As part of the Firm's investment advisory services, PrimeTRUST may recommend that you use the
services of a third-party investment adviser ("TPA") to manage a portion of the Retirement Plan
investment portfolio. Factors that the Firm takes into consideration when making the
recommendation(s) include the following: the TPA's performance and experience, methods of
investment analysis, fees, your financial needs, investment goals, risk tolerance, and investment
objectives. The Advisor will periodically monitor the TPA(s)' performance to ensure its management
and investment style remains aligned with your investment goals and objectives.
Consulting Services
PrimeTRUST provides fee-based consulting services for Institutional Clients that sponsor a Retirement
Plan. The Firm gathers extensive information on each plan at the commencement of an engagement to
determine which of the Firm's services can benefit the Plan Sponsor. PrimeTRUST outlines a
recommended scope of work for the consulting project for approval by the Plan Sponsor. The specific
details of any engagement to provide consulting services are agreed upon in writing prior to the
commencement of the project and are subject to the terms and conditions of a Consulting Agreement.
These services, some of which are discussed below, may be provided separately or in combination
with one another, depending on the needs of the Plan Sponsor.
•Plan Service Provider Evaluation and Plan Fees Review
This process helps fiduciaries to satisfy one of their primary fiduciary duties -- to assure that
plan fees and expenses are fair and reasonable within the context of the services provided.
PrimeTRUST can be engaged on a one-time basis to evaluate your Retirement Plan service
provider. The Firm does this by taking an inventory of the services offered to your Retirement
Plan, evaluating the multitude of service functions, assigning a "value" score for each of the
major service components, and rendering an overall evaluation score of your existing service
provider and comparing that score to a peer group of service providers. As part of the project,
PrimeTRUST reviews and evaluates your existing plan fee and expense arrangements,
including trustee/custodial fees, record keeping fees, administration and investment related
fees.
The centerpiece of the study is the Firm's proprietary cost/benefit analysis which enables
fiduciaries to better determine the value proposition of their existing services provider(s). The
Firm's analysis will be based on information supplied by you, your service provider(s), and third-
party databases.
•Defined Benefit Pension Plan Management
PrimeTRUST provides a process-oriented consulting service for Plan Sponsors who need
assistance managing their pension plan throughout the wind-down phase to the plan's eventual
termination or restoration to its fully funded status. This includes determining plan sponsors
goals, then designing and implementing a multi-year project management plan incorporating
establishing the plan's funding policy, investment policy, benefit design management,
supervising asset liability studies, developing liability driven investment strategies, and
coordinating the steps for formal plan termination process.
PrimeTRUST helps fiduciaries by coordinating, guiding and monitoring the activities of the
plan's actuary, attorney, accountant, corporate finance executive team, investment manager,
and the administration and recordkeeping firm. The Firm's proprietary Quarterly Plan
Performance Monitoring Reports track the project plan's progress using metrics key to the
plan's successful outcome; including reporting on sources of change to the plan's funded
status, funding schedules for the plan year and calendar year, summary trust report statement
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of contributions and distributions, and investment performance reviews to customized relevant
pension plan benchmarks.
•Plan Service Provider Search and Recommendation
PrimeTRUST will work with the Plan Sponsor, named fiduciary or investment committee
(hereafter, referred to as the "Responsible Plan Fiduciary") to establish selection criteria for
conducting a search of retirement plan service providers based upon the plan's service
requirements and benefit resource needs. The Advisor will identify and screen potential service
providers, benchmarking each according to the agreed upon selection criteria and score them
accordingly. The Advisor will then make a recommendation to Responsible Plan Fiduciary for
their consideration in making a final decision.
•Employee Education
For pension, profit sharing and 401(k) plan Clients designed to allow individual plan participants
to exercise control over assets in their own account ("self-directed plans"), PrimeTRUST may
also provide periodic educational support and investment workshops designed for the plan
participants. The nature of the topics to be covered will be determined by PrimeTRUST and the
Client but will be limited to those activities that are educational in nature.
•Fiduciary Education and Training
PrimeTRUST can provide fiduciary education and training to the fiduciaries of the plan. Such
training will include comprehensive discussion and supplementary handout materials pertaining
to topical fiduciary issues including: identification of fiduciaries, discussion of fiduciary duties,
responsibilities and liabilities under ERISA, presentation of a "blue print" for procedural
prudence, fiduciary risk management strategies and approaches to delegating responsibility to
a prudent expert.
C. Advisory Services Offered – Individual Clients
PrimeTRUST Advisors offers fee-based investment advisory and consulting services to Individual
Clients in need of financial planning or investment advisory services.
Financial Planning Services
PrimeTRUST offers financial planning services which typically involve providing a variety of advisory
services to Clients regarding the management of their financial resources based upon an analysis of
their individual needs.
These services can range from broad-based financial planning to consultative or
single subject planning.
Financial planning is a process that focuses on ascertaining a Client's financial goals and then
developing a written plan to help the Client achieve those goals. A written financial plan is created by
the Firm to carry an individual Client from his or her present financial position to the attainment of
financial goals. Since no two Clients are alike, the plan must be designed for the individual, with the
Advisor's recommended strategies tailored to each particular Client's needs, abilities, and financial
goals.
Financial plans will vary based on the information provided by the Client. If you retain PrimeTRUST for
financial planning services, the Firm will meet with you to gather information about your financial
circumstances and objectives. PrimeTRUST may also use financial planning software to determine
your current financial position and to define and quantify your long-term goals and objectives. Once
your specified long-term objectives (both financial and non-financial) are identified, the Firm will
develop shorter-term, targeted objectives. PrimeTRUST will deliver a written plan to you, designed to
help you achieve your stated financial goals and objectives.
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Financial planning and consulting recommendations may pose a conflict between the interests of the
Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for
investment management services or to increase the level of investment assets with the Advisor would
pose a conflict, as it would increase the advisory fees paid to the Advisor. Similarly, a recommendation
to purchase an insurance product for which the Firm receives a commission would pose a conflict.
Clients are not obligated to implement any recommendations made by the Advisor or maintain an
ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made
by the Advisor, the Client is under no obligation to effect transaction through the Advisor.
Investment Management Services
PrimeTRUST offers discretionary investment advisory and asset allocation services tailored to meet
the Firm's individual Clients' needs and investment objectives primarily using mutual funds and
exchange-traded funds.
The Firm provides advice in connection with one or more of the following items as needed:
•Selection and establishment of investment account arrangements,
•Organization on the use and purposes of various financial accounts,
•Manage rollovers, transfers, or distributions to/from accounts,
•The investment of assets that are rolled over or otherwise transferred or distributed to accounts,
•Acquiring, holding, disposing of investment assets within investment accounts,
•Management of the investments, including strategies and portfolio composition
If you participate in the Firm's discretionary portfolio management services, PrimeTRUST requires you
to grant the Firm discretionary authority to manage your account. Discretionary authorization will allow
the Firm to determine the specific securities, and the amount of securities, to be purchased or sold for
your account without your approval prior to each transaction. Discretionary authority is typically granted
by the investment advisory agreement you sign with the Firm and the appropriate trading authorization
forms. You may limit the Firm's discretionary authority (for example, limiting the types of securities that
can be purchased or sold for your account) by providing PrimeTRUST with your restrictions and
guidelines in writing.
PrimeTRUST may also offer non-discretionary portfolio management services. If you enter non-
discretionary arrangements with PrimeTRUST, the Firm must obtain your approval prior to executing
any transactions on behalf of your account. You have an unrestricted right to decline to implement any
advice provided by the Advisor on a non-discretionary basis.
As part of the Firm's investment management services, in addition to other types of investments,
PrimeTRUST may invest your assets according to one or more model portfolios developed by
PrimeTRUST. These models are designed for investors with varying degrees of risk tolerance ranging
from a more aggressive investment strategy to a more conservative investment approach. Clients
whose assets are invested in model portfolios may not set restrictions on the specific holdings or
allocations within the model, nor the types of securities that can be purchased in the model.
D. IRA Rollover Recommendations
For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02")
where applicable, PrimeTRUST provides the following acknowledgment to Individual Clients.
When PrimeTRUST provides investment advice to Clients regarding their retirement plan account or
individual retirement account, PrimeTRUST is a fiduciary within the meaning of Title I of the Employee
Retirement Income Security Act and/or the Internal Revenue Code, as applicable. These are laws and
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regulations governing retirement accounts. The way in which PrimeTRUST generates its income
(gathering assets under the Firm's management) creates some conflicts of interest with Clients who
are holding assets in IRAs and 401(k)-type account that are not under the Firm's management. To
mitigate this conflict, PrimeTRUST operates under special rules that requires the Firm to act in a
Client's best interest when making recommendations for 401(k)/IRA Rollovers and not put
PrimeTRUST's interest ahead of the Client. Under this special rule's provisions, the Firm must:
•Meet a professional standard of care when making investment recommendations (give prudent
advice),
•Never put the Firm's financial interests ahead of a Client's when making recommendations (give
loyal advice),
•Avoid misleading statements about conflicts of interest, fees, and investments,
•Follow policies and procedures designed to ensure that the advice given is in a Client's best
interest,
•Charge no more than is reasonable for the Firm's services; and
•Provide Clients with basic information about conflicts of interest.
PrimeTRUST benefits financially from the rollover of Client assets from a retirement account to an
account that the Firm manages or provides investment advice, because the assets increase the Firm's
assets under management and, in turn, the Firm's advisory fees. As a fiduciary, PrimeTRUST
recommends a rollover only when the Firm believes it is in a Client's best interest.
E. Client Account Management
Prior to engaging PrimeTRUST to provide investment advisory, consulting or financial planning
services, each Client is required to enter into one or more agreements with the Firm and the Client.
These advisory services may include:
•Investment Management Services for Institutional Clients
•Investment Management Services for Individual Clients
•Consulting Engagements
•Financial Planning Services
F. Types of Investments
PrimeTRUST primarily offers advisory services on mutual fund and exchange-traded fund products.
A mutual fund is a financial vehicle that pools assets from individual investors to invest in securities like
stocks, bonds, money market instruments, and other assets. Mutual funds give small individual
investors access to professionally managed portfolios of equities, bonds, and other securities. Each
investor, therefore, participates proportionally in the gains or losses of the fund.
Mutual funds are operated by professional money managers, who allocate the fund's assets and
attempt to produce capital gains or income for the fund's investors. A mutual fund's portfolio is
structured and maintained to match the investment objectives stated in its prospectus.
An exchange-traded fund (ETF) is a type of pooled investment security that operates much like a
mutual fund. Typically, ETFs will track a particular index, sector, commodity, or other asset, but unlike
mutual funds, ETFs can be purchased or sold on a stock exchange the same way that a regular stock
can.
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An ETF can be structured to track anything from the price of an individual commodity to a large and
diverse collection of securities. ETFs can even be structured to track specific investment strategies.
Additionally, PrimeTRUST may advise you on any type of investment that the Advisor deems
appropriate based on your stated goals and objectives. The Advisor may also provide advice on any
type of investment (including individual securities) held in your portfolio at the inception of your
advisory relationship with PrimeTRUST.
You may request that the Advisor refrain from recommending particular securities or certain types of
securities for investment. You must provide these restrictions to the Firm in writing.
G. Wrap Fee Programs
PrimeTRUST does not manage or place Client assets into a wrap fee program. Investment
management services are provided directly by PrimeTRUST.
H. Assets Under Management
As of December 31, 2023, PrimeTRUST provides continuous management services for $15,562,029 in
Client assets on a discretionary basis, and $283,438,977 in Client assets on a non-discretionary basis.
PrimeTRUST provides investment advice to defined benefit pension, 401(k) profit sharing and 403(b)
plans with respect to assets having an aggregate value of approximately $299 million.