TFO is owned by TFO Partners, Inc. Mr. Christopher Erblich is the control person of TFO Partners, Inc.
TFO has been providing advisory services since October 2011.
As of December 31, 2023, TFO managed $3,810,701,750 on a discretionary basis, and $13,361,542
on a non-discretionary basis.
Investment Management Services:
TFO manages investment portfolios for a wide variety of clients and their accounts, including
individuals, qualified retirement plans, trusts, charitable organizations, small businesses and
corporations. TFO will work with a client to determine the client's investment objectives and investor
risk profile and generally will design a written investment portfolio summary. TFO uses a variety of
tools, including investment and portfolio allocation software to evaluate alternative portfolio designs.
TFO evaluates the client's existing investments with respect to the client's investment objectives. TFO
works with new clients to develop a plan to transition from the client's existing portfolio to the desired
portfolio. TFO 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 will create a portfolio consistent with the client's investment objectives and will allocate the client's
assets among various investments, taking into consideration the specific objectives and preferences of
the client. TFO primarily creates portfolios consisting of no-load mutual funds, exchange traded funds
(ETFs), and managed accounts of individual equities/bonds managed by third-party advisors. 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 retained
for personal reasons. These situations will be specifically identified in the client's Investment Portfolio
Summary ("IPS"), if one is utilized, or otherwise documented and may be designated as non-managed
assets in certain cases.
TFO manages portfolios on a discretionary, and in limited cases, on a non-discretionary basis,
according to the desires of the client. A client may impose any reasonable restrictions on TFO's
discretionary authority, including restrictions on the types of securities and specific securities to be
used in the client's portfolio.
In certain circumstances, TFO may allocate a portion of a portfolio to an independent third-party
investment advisor ("separate account manager") when appropriate for the client's circumstances and
objectives, including, but not limited to, client account size, tax circumstances and type of investments.
Upon the recognition of such situations, in coordination with the client, TFO may hire a separate
account manager or enter into a tri-party agreement with the client and separate account manager for
the management of those securities. In some cases, separate account managers may have entered
into a sub-advisory agreement with TFO.
TFO will monitor the performance of the selected separate account manager(s). If TFO determines that
a particular selected separate manager is not providing appropriate 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 will remove the client's assets from that selected separate account
manager (if a discretionary account) or recommend the client remove assets from the manager (if a
non-discretionary account). TFO may then recommend placing the client's assets with another
investment manager. Clients may be required to execute documents to re-allocate assets amongst
separate account managers. For non-discretionary accounts, TFO will make recommendations to the
client as appropriate.
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On an ongoing basis, TFO will answer clients' inquiries regarding their accounts and review the
performance of their accounts periodically with clients. TFO will periodically review clients' investment
objectives risk profile and discuss the re-balancing of each client's accounts to the extent appropriate.
TFO will provide to the separate account manager any updated client financial information or account
restrictions necessary for the manager to provide services.
In addition to managing the client's investment portfolio, TFO provides 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, financial
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 often times reviews the adequacy of current life insurance, long-term care and disability coverage,
help to determine future needs, and may recommend working with a third party provider that offers
insurance products. Clients have no obligation to purchase any insurance products we recommend.
Family Office Services:
In addition to investment management services described above, TFO also provides Family Office
services to select clients. These services may include some or all of the following:
analysis of private investments, family governance consulting, philanthropic consulting, coordination
among other service providers engaged by the client (legal, estate, tax, accounting, insurance and
banking), coordination of cash management services, advice and reporting requested by the client.
Family Office services are not offered to all TFO clients. TFO also provides additional non-investment
advisory services to some clients as part of the Firm's Family Office Services. See Item 10 for
additional information.
Family Office Advisory Consulting Services:
TFO offers a combination of family office and advisory consulting services to select clients. These
services may include some or all of the following:
1. Assist client in opening accounts as requested by the client;
2. Discuss with client investment options,
3. Implement with client's approval the investment program as outlined by the client;
4. Coordinate cash management matters with the client's personal banker or any other banking
entity as directed by the client;
5. Assist client with accessing available
reports;
6. Providing to the client available financial reports and tax documents as requested by the client;
7. Assist in the coordination of estate and income tax planning with client's designated Estate
and/or Tax Advisors
Family Office Advisory Consulting services are not offered to all TFO clients. TFO also provides
additional non-investment advisory services to some clients as part of the Firm's Family Office
Services. See Item 10 for additional information.
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Retirement Plan Services:
TFO also provides advisory services to participant-directed employee retirement benefit plans. TFO's
services may include, but are not limited to, one or more of the following: analysis of the plan's current
investment platform, assisting the plan in creating an investment portfolio summary defining the types
of investments to be offered and the restrictions that may be imposed, recommending and
periodically reviewing the plan's investment options, specific investment advice to plan participants,
coordinating with the plan's service providers to implement investment strategies, participant
education and performance monitoring. In certain circumstances, TFO 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 Plan 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), TFO
is required to provide the Plan's responsible fiduciary (the person who has the authority to engage TFO
as an investment adviser to the Plan) with a written statement of the services TFO provides to the
Plan, the compensation TFO receives for providing those services, and TFO's status (which is
described below).
The services TFO provides to the Plan are described above and in the service agreement that the
client signed with TFO. TFO's compensation for these services is described below, at Item 5, and in
the service agreement. TFO may, with consent of the Plan, and in accordance with Plan documents,
bill out of pocket expenses (such as overnight mailings, messenger fees, etc.) at cost. TFO does not
reasonably expect to receive any other compensation, direct or indirect, for the services it provides to
the Plan or Plan Participants.
In providing services to the Plan and Plan Participants, TFO's status is that of an investment adviser
registered under the Investment Advisers Act of 1940, and TFO is not subject to any disqualifications
under Section 411 of ERISA. In performing ERISA fiduciary services, TFO may act as either a non-
discretionary fiduciary or a discretionary fiduciary of the Plan as both are defined in Section 3(21)(A). In
some cases, TFO may act as a discretionary "investment manager" of the Plan as defined in Section
3(38) under ERISA.
Consulting Services:
Clients can also receive financial 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, tax compliance and planning, annuity advice or any other specific topic. TFO 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 TFO to provide additional services, such as investment
advisory services or retirement plan services.
Educational Seminars and Workshops:
TFO offers an educational program, TFO Life Academy, which includes topics on financial literacy. The
program is generally offered to clients as a part of a package of other advisory services. TFO may also
offer the program as a standalone service or part of a consulting package for a flat fee.
Non-Investment Advisory Referrals:
TFO has partnered with PinnacleCare, a health care concierge service provider to offer its clients
access to PinnacleCare's services. TFO may refer clients in need of such service to PinnacleCare, and
in such cases, will pay up to $1,000 of PinnacleCare's fees. TFO has also contracted with Gallagher
Benefit Services to assist clients regarding health insurance questions/ help evaluating individual
coverages or Medicare. TFO will pay all associated costs for all clients contracted within TFO's
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agreement with Gallagher. TFO does not have any affiliation with either PinnacleCare or Gallagher
Benefit Services nor does it receive any compensation for referrals. Clients are under no obligation to
use PinnacleCare or Gallagher Benefit Services' services.
Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
following acknowledgment to you. When we provide investment advice to you regarding your
retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I
of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable,
which are laws governing retirement accounts. The way we make money creates some conflicts with
your interests, so we operate under a special rule that requires us to act in your best interest and not
put our interest ahead of yours. Under this special rule's provisions, we must:
Meet a professional standard of care when making investment recommendations (give prudent
advice).
Never put our financial interests ahead of yours when making recommendations (give loyal
advice).
Avoid misleading statements about conflicts of interest, fees, and investments.
Follow policies and procedures designed to ensure that we give advice that is in your best
interest.
Charge no more than is reasonable for our services; and
Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.