A. Our Company TRUE Private Wealth Advisors, LLC, Inc. ("TPWA," "Adviser," or the "Firm") is a privately held Oregon corporation that began providing investment advisory services in 2012. TPWA's current indirect beneficial principal owners are:
•Stephen Altman,
•Brett Davis,
•Todd Gescher, and
•Jason Herber. This Brochure provides important information about TPWA, its services and compensation, the costs of participating in its programs, and situations where conflicts exist between the interests of its Clients and the interests of the Firm or its investment adviser Representatives (each a "Representative"). Clients should pay particular attention to these conflicts of interest because they can affect certain aspects of TPWA's or its Representative's decision-making in managing the Client's account, in recommending a custodian or choosing a broker for the account, and in making investment recommendations, among other important considerations.
Keep in mind that a number of separate businesses provide the various investment products and services described in this Brochure. These businesses' legal, contractual, and regulatory obligations differ in important ways, depending on whether, in providing the product or service, the business is acting as an investment advisor, custodian, or insurance company. Clients (including prospective Clients) who have questions about the entities, relationships, services or other information described in this Brochure should contact their Representative at the email address, telephone number, or street address shown on the Brochure Supplement provided by the Representative. You can also reach our management, including our Compliance Officer, by telephone at (503) 400-3330, by email at [email protected], or by mail at the address shown on the front of this Brochure.
About Our Firm TPWA was founded by independent-minded financial advisors who believe the current "Wall Street" model for financial firms is broken and understand that success can be achieved in unique ways. Clients work with one of our Advisory Groups. Each Advisory Group is comprised of one (or more) Representative(s), plus team members ready to support the Client's needs. Because Clients often work with more than one registered individual, we use the term "Representative" to refer collectively to all of the investment adviser Representatives with whom a Client will work.
Each Advisory Group develops and manages the model portfolios and strategies for its Clients' accounts, subject to TPWA's Investment Committee's general oversight. The Representative works closely with a particular Client in identifying Client goals and objectives, in articulating any Client-requested investment restrictions or requirements, and in developing the initial portfolio consistent with Client needs and objectives.
B. Our Services TPWA offers access to a wide range of investment solutions through the following programs and services:
•Investment Management Program
•Financial Planning Services 4
•Institutional & Other Consulting Services
•Educational Courses and Seminars Please note the information in this Brochure is necessarily general and does not address all details of TPWA's programs and services. Because many aspects of a Client's "Advisory Agreement" with us are negotiable, Clients should always refer to their individual Advisory Agreement for terms that apply specifically to them.
1. Investment Management Program Through the Investment Management Program ("IM Program" or simply, "Program"), TPWA offers Clients a fully discretionary managed account solution based on model portfolios allocated across equity, fixed income, alternative, and cash asset classes, as the Representative detemines suitable for the Client. For many Clients, the Advisory Group assigned to the Client is able to meet the Client's investment needs through a managed portfolio of mutual funds and exchange-traded funds ("ETFs") (and in the Representative's discretion to meet the needs of the client, unit investment trusts ("UITs"), closed-end funds, money market funds or cash management investments) that reflect a careful selection and allocation of the Client's account among key asset classes and, where necessary, weighting in particular sectors, according to one of the Advisory Group's model portfolios. Clients who own variable annuities may have corresponding variable annuity sub-accounts in their account; however, the purchase of a variable annuity is not a requirement of our Program. TPWA permits each Advisory Group, in its discretion, to develop model portfolios comprised of additional asset classes, and additional investment selections based on factors such as market capitalization, industry sector, and style categories, as necessary to meet Client needs. Where necessary to meet the needs of a Client seeking to increase portfolio diversification or exposure to asset classes not correlated wth the broader equity markets or with interest rates, for example, the Representative may recommend a range of mutual funds and ETFs (invested in alternative asset classes, such as real estate, and/or commodities, such as precious metals, for example) to identify suitable additions to a portfolio. Additionally, each Advisory Group is permitted, in its discretion, to develop model portfolios (each referred to as an "Extended Portfolio") that implement the Client's portfolio allocation in that one or more asset classes represented by invest in individual securities (e.g., individual stocks, bonds, or other securities). Clients should not expect the Advisory Group to select individual securities (other than mutual funds, ETFs, UITs, closed-end funds, money market funds or cash management investments) for their portfolio unless they discuss the requirements and risks of a portfolio of individual securities with their Representative in advance and acknowledge such risks.
Refer to Item 8, Methods of Analysis, Investment Strategies and Risk of Loss for information regarding requests to allocate a portion of Client's portfolio to so-called "ESG" assets (that is, investments focused on Environmental, Social, and Governance issues), or to so-called "Digital" assets (an asset that is issued or transferred using distributed ledger or blockchain technology ("distributed ledger technology"), including, but not limited to, so-called "virtual currencies," "coins," and "tokens." In general, Client portfolios are not allocated to ESG investments, except upon the the Client's specific request, as provided Item 8. As discussed in Item 8, TPWA has not currently approved any digital assets for Client discretionary portfolios in the Investment Management Program.
Managed Accounts & Advised Accounts; Custodian To participate in the IM Program, the Client must enter into an Advisory Agreement with TPWA that describes the advisory services to be provided, the Advisory Fees, Platform Fees, and other fees and expenses the Client will pay or incur, and other terms and conditions of the Client's relationship with TPWA, all of which are negotiable in TPWA's sole discretion. Refer to Item 5 for additional information regarding fees and expenses. 5 Client must deposit, transfer or deliver to a qualified custodian reasonably acceptable to TPWA (the "Custodian") the assets to be managed or supervised by TPWA on a discretionary basis (together with income, gains, and additions, is referred to as the "Managed Assets"), and enter into an agreement (the "Custodial Agreement") with the Custodian to maintain such assets in one or more accounts in Client's name (each a "Managed Account").
We recommend the custodial and brokerage services of Fidelity Brokerage Services, LLC and National Financial Services, LLC, both broker-dealers, members FINRA/SIPC, affiliates of Fidelity Investors (jointly "Fidelity"). Fidelity and TPWA are not affiliated. For investments in subaccounts of variable annuities, the insurance company (or its transfer agent) serves as the Custodian. Clients are not required to purchase a variable annuity to participate in the IM Program; however, certain investments are only available as subaccounts of a variable annuity. Refer to Item 12 for further information regarding brokers and brokerage services.
From time to time, Client may identify to TPWA certain investment accounts (typically, but not exclusively, retirement or employee benefit accounts) with respect to which Client requests TPWA's investment advice, but which TPWA is not able to manage on a discretionary basis or place trades. Under those circumstances, TPWA may, in its discretion, agree to provide non-discretionary investment recommendations with respect to the assets (the "Advised Assets") maintained with the plan administrator, trustee, or other qualified custodian of each such "Advised Account," to be negotiated on a Client-by-Client basis, depending on the nature of the Advised Account and Advised Assets, and the frequency of monitoring and recommendations requested by the Client. If Client wishes to implement TPWA's ideas or recommendations with respect to the Advised Assets, Client will have sole responsibility for placing trades with the appropriate plan administrator, trustee, or other qualified custodian, or their designated broker or other financial intermediary, in order to buy, sell, or exchange investments maintained as Advised Assets.
Other Non-Discretionary Accounts In its sole discretion, TPWA may also agree to accept non-discretionary accounts for which TPWA is able to place the trades, if the Client accepts TPWA's recommendations. Such accounts shall be considered as Managed Accounts, since the Assets are considered as assets under management. Client should be aware that because of the time delays involved in obtaining Client consent for trades for non-discretionary accounts, TPWA's policies provide for it to place orders for discretionary accounts before contacting Clients of non- discretionary accounts for their consent. Although this practice is not expected to affect investments in mutual funds (which should obtain the same daily NAV price), it may create a material difference between discretionary and non-discretionary accounts in prices received for other types of investments where prices are set by the trading markets throughout the day. Although it is not possible to predict whether Accounts whose orders are submitted earlier will always receive a more favorable price in every instance, TPWA believes this may often be the case. Consequently, discretionary accounts may perform materially better than non- discretionary accounts over time as a result of discretionary orders being submitted earlier.
Subadvisers, Third-Party Managers, and Third-Party Programs In its discretion, TPWA is authorized to engage one or more investment managers (each a "Subadviser," also referred to as a "Manager"), which TPWA may engage as its subadviser. TPWA may delegate the discretionary management of all or part of any Account, based upon the Account's stated investment objective and risk/volatility parameter, without prior consultation with the Client and without the Client's prior consent. In TPWA's discretion, it may grant a Manager authority to further delegate such discretionary investment authority to additional Managers. Each such Manager shall have limited power-of-attorney and trading authority over the Assets directed to them for management and shall be authorized to buy, sell, and trade in securities in accordance with the Account's investment objective and risk/volatility parameter as communicated by TPWA (or its delegating Manager), and to give instructions in furtherance of such trading authority to each Broker- Dealer and Custodian.
6 In most arrangements involving Subadvisers, Client will generally not have a direct agreement with the Subadviser. In those cases, advisory fees charged by a Subadviser will usually be added by TPWA to the Advisory Fees Client owes to TPWA, and will be deducted by TPWA and paid from the Account. However, from time to time, the investment programs of certain sponsors will require the Subadviser to enter into a subadvisory agreement with TPWA, and will also require the Subadviser to enter into a direct agreement with the Client. In addition to the subadviser arrangements, TPWA may also approve from time to time one or more investment program(s) (each a "Third-Party Program") sponsored by a third-party investment firm (each a "Sponsor"), through which the Assets will be allocated to one or more third-party investment managers available through the Third-Party Program (referred to as a "Third-Party Manager," also referred to as a "Manager"). In a Third- Party Program, Client's relationship with TPWA will be governed by the Advisory Agreement; however, Client's relationship with respect to the Sponsor and each Manager will be governed by and subject to the terms of the separate agreement (the "Third-Party Program Agreement") between Client, the Sponsor, and in some programs, the Manager(s). Each Manager designated for the Client will manage the Managed Assets allocated to the Manager, according to the Manager's designated investment portfolio and style. The Client will receive from the Sponsor or Manager the Form ADV Part 2A Brochure of the Sponsor, and the Brochure of each Manager engaged to manage Client's Assets.
Outsourced Insurance TPWA has engaged a third party company that provides outsourced insurance solutions. TPWA uses this solution to manage insurance products for its Clients, including 529 plans and annuities. Periodically, upon request from the third party, TPWA provides advice with respect to model portfolios, sub-account allocations, re-allocations among available investment options, and the timing thereof. The third party has the sole responsibility to determine whether, and if so, how to use any advice provided by TPWA and will take sole responsibility for any recommendations to clients. TPWA is compensated with a flat fee of $1,125 per calendar quarter end for providing advice to the third party regarding the management of its Client's insurance products.
Suitability Information and Account Management The Representative will obtain from the Client information about the Client's overall personal and financial situation, and with respect to the Managed Accounts at each Custodian, information regarding the Managed Account's investment objective and risk/volatility parameter to guide the Representative's management of such Managed Accounts. The information TPWA and Representative request regarding the Client's personal and financial situation, and the investment objective and risk/volatility parameter for each Managed Account, and any additional information TPWA or the Representative request is referred to collectively as the "Suitability Information." The Representative will work with the Client to designate one (or more) model portfolios (each a "Portfolio") developed by the Representative's Advisory Group that is suitable for investment of the Managed Assets allocated to each Managed Account, except as managed by a Manager. To meet the needs of the Client, the Representative (through the Representative's Advisory Group), may modify an existing model portfolio or blend two or more existing model portfolios to achieve desired characteristics for a Managed Account. For an Extended Portfolio, the Representative will discuss with the Client the proposed types of individual securities (e.g., domestic large cap stocks, domestic small cap stocks, municipal bonds) in addition to mutual funds and ETFs the Representative expects to purchase for the Managed Account. The Advisory Group will manage the Managed Account in a manner reasonably intended to achieve over time the Managed Account's long-term investment objective, consistent with its parameter for risk/volatility, and the Client's reasonable investment restriction, if any, imposed by Client in writing.
Depending on the customization and complexity of each Portfolio, TPWA, through its Advisory Groups generally manages a Client's Managed Accounts on an aggregate basis across all Managed Accounts (the "Household" basis). TPWA establishes targets aggregated across all Managed Accounts at the same 7 Custodian (or even, across Custodians, in its discretion). However, at any time, TPWA retains the discretion to change the basis for managing and reporting Managed Accounts from a Household basis to an account-by- account basis, and vice versa. TPWA may use blended targets as tools for evaluating overall portfolio concentration, sensitivity to interest rates, and specific targets for Accounts and other forms of analysis.
Portfolio Investments TPWA has discretion to select the investments that will be used for each of the asset classes in a Portfolio. The investments will be represented by investment company securities, including mutual funds and ETFs (or similar subaccounts of variable annuities, if Client owns such an annuity), as well as, in the Representative's discretion where suitable for the client, closed-end funds, money market funds, or cash management investments; however, depending on the Client's needs, a broader range of investments, and where suitable and the Representative determines appropriate to meet the needs of the portfolio, individual securities. For Clients with large or complex holdings, TPWA may, in its discretion, expand Portfolio composition to include additional asset classes, including commodities (such as precious metals, for example), or hedge funds or private equity funds, among other examples. Because Representatives have a significant influence over their Clients' Portfolio investments, Clients who

are interested in a broader range of asset classes or securities should be sure to discuss with their Representative the availability and limitations on the use of specific investments or types of securities in which the Client is interested, whether alternative class mutual funds or ETFs, or individual securities, such as stocks or bonds, or more sophisticated investments, such as physical commodities or private funds, among others. As discussed above, Clients with an Extended Portfolio are permitted to have a portion of their Portfolio implemented through investments in individual securities. Ancillary Services From time to time, Clients may request the Representative to provide advisory services ("Ancillary Services") that involve managing Assets held in a Managed Account outside of the asset classes provided according to the Managed Account's designated Portfolio. Sometimes, the request involves assets maintained with a different Custodian. The requests may involve legacy assets acquired prior to the Client's Advisory Agreement or new assets TPWA is asked to acquire and manage for the Client.
TPWA's acceptance of requests for Ancillary Services is subject to its discretion. The Firm and Representative evaluate requests for Ancillary Services on a Client-by-Client and case-by-case basis, based on a variety of factors, including the nature and size of the Client's account and prospect for additional assets or Client referrals, any difficulties in providing the services, whether the size of the assets to be managed and fees to be received are commensurate with the additional management, compliance, and administrative burdens, among other factors. If TPWA and Representative agree to such request, in their discretion, TPWA and the Client will negotiate the terms and TPWA's fee for such Ancillary Services. Unless additional documentation is deemed appropriate due to the nature of the asset or services, the Ancillary Services will be governed by the Client's Advisory Agreement and an Addendum required to reflect the agreed Advisory Fee, Custodian, and other business terms with respect to the Ancillary Services.
The Fidelity IPO service is an example of an Ancillary Service that Representatives are permitted to provide for their Clients, in their discretion. If a Client requests and their Representative determines they meet suitability requirements (including financial situation and knowledge about investing in IPOs) and determines, in his or her discretion, an IPO investment is appropriate for the Client's portfolio (an "IPO Client"), the IPO Client may participate in the Fidelity IPO service in which the IPO Client submits an indication of interest to purchase securities in an initial public offering (IPO). Although selection of the IPO Client's indication of interest is remote, if selected, the indication of interest becomes an immediate good order and filled. Clients should understand that for each Representative, few Clients meet the suitability and portfolio requirements to be an IPO Client permitted to participate in the Fidelity IPO service; as a result, the few IPO Clients will be the only Clients permitted to participate in the Fidelity IPO service and acquire IPOs. Client should contact their Representative for further information.
8 Discretionary Account All Managed Accounts are fully discretionary, except a Managed Account TPWA agrees to accept on a non- discretionary basis, as described above. In a discretionary account, the Client grants TPWA and the Representative full authority and discretion to manage the Managed Assets and Managed Account, without prior consent or notice to Client, according to the terms of the IM Program, the Advisory Agreement, and any other IM Program documents, Suitability Information, and other information provided to TPWA and Representative from time to time. TPWA and the Representative will provide continuous and regular supervisory or management services with respect to the Managed Assets in an effort to seek to achieve the investment objective of the Managed Account consistent with its parameter for risk/volatility. TPWA and the Representative may elect to change (on either a temporary or permanent basis) the asset classes and sub- classes, class weightings, credit quality, duration, market sector, style, volatility (risk characteristic), interest rate sensitivity, issuer, security types, and other characteristics or parameters of the investments comprising a Portfolio, or Extended Portfolio all without prior notice or consent of the Client.
Authority Regarding Managers and Programs Client will authorize TPWA to "hire and fire," add, terminate, replace, and change any Manager, whether as Subadviser or Third-Party Manager, in a subadvisory program, in a Third-Party Program, or otherwise, when, in our sole discretion, we believe such action is in Client's or any Account's best interest. TPWA will review and monitor the Accounts managed by each Manager, and for which services TPWA shall be paid its Advisory Fee and Platform Fee (described below) with respect to the Assets managed by each Manager.
Clients interested in a Subadviser or Third-Party Program will receive from the Representative information regarding an available Subadviser or Third-Party Program and available Manager(s) in which the Client is interested. Once the Client's needs and objectives have been identified. Client will authorize the Custodian maintaining Assets managed by a Subadviser or Third-Party Manager to provide account statements and confirmations of transactions (electronically or via internet) to TPWA and the Representative, along with an indication that account statements have been sent to the Client, and to permit TPWA and the Representative to electronically view and download account information. Client will grant TPWA and the Representative unrestricted access to such account information.
Please refer to Item 8 for information about TPWA's methods of analysis and investment strategies, the types of investments TPWA generally recommends, and the material risks involved with respect to the Investment Management Program. Refer to Item 12 for information regarding brokerage. 2. Financial Planning Services Clients in our IM Program receive general financial planning advice through on-going meetings and discussions with the Representative. The primary purpose of this advice is to inform and support our investment management services. There is no additional charge for the general planning services for IM Program Clients.
For IM Program Clients who would like more in-depth financial planning services than their Advisory Group includes as part of their IM Program, whether on a particular topic or with respect to the Client's overall financial planning, or for non-IM Program Clients who desire financial planning services, TPWA offers fee- based financial planning services (the "Financial Planning Services") covering a range of financial planning services. The Financial Planning Services may include any one or more of the following: 9 FINANCIAL PLANNING SERVICES Business PlanningInvestment Consulting Cash Flow Forecasting Insurance Needs Analysis Asset Allocation Retirement Plan Analysis Retirement PlanningCharitable Giving Estate Planning Risk Management Financial ReportingDistribution Planning TPWA and the Client will enter into a written Advisory Agreement that describes the specific Financial Planning Services TPWA will provide, the Advisory Fees for such services, and whether any written report or financial plan, whether in hard copy or an electronic format, will be provided. A written or electronic report or financial plan will not be provided, unless specifically provided in the Advisory Agreement.
Through our fee-based Financial Planning Services, the Representative will meet with the Client to discuss and analyze the Client's investments and financial situation, and help the Client to identify his or her investment goals and objectives, tolerance for risk, and investment time horizon, among other key factors to developing a financial plan. Clients may be asked to provide detailed information about the Client's personal and family situation, estate and retirement plans, trust agreements, wills, investments, insurance, or other information necessary to provide the specific services requested. Based on the information provided by the Client, the Representative will develop recommendations to help the Client towards achieving his or her investment objectives. Please note the Financial Planning Services are not intended to be a "comprehensive financial plan" unless specifically stated in the Advisory Agreement.
Reliance on Information from Client, Other Professionals & Planning Assumptions In providing the Financial Planning Services, TPWA and the Representative will rely on assumptions and estimates regarding a number of important factors that may or may not turn out to be accurate at any time. These assumptions will often include subjects such as future market performance and investment returns, anticipated and reasonably foreseeable living and medical expenses, tax laws, interest rates, and other factors.
TPWA and the Representative will also rely on information provided by Client and Client's other professionals (e.g., attorneys, accountants, etc.).
TPWA does not verify information received from the Client or from such other professionals, and TPWA is expressly authorized to rely on such information. As a result of likely differences between the items assumed and the actual situation at any time in the future, Client's (or Client's successors') financial situation or needs may be materially different than anticipated and Client's financial or investment objectives may not be achieved. Clients are advised that it remains their responsibility to promptly notify TPWA of material changes in their financial situation or investment objectives, to allow for reviewing, evaluating, or revising TPWA's previous recommendations or services.
If the Advisory Agreement provides for a report or financial plan, it will usually include recommendations to assist the Client in achieving his or her financial goals and objectives through purchasing or selling investments, purchasing new or revising existing insurance products or policies, establishing or participating in tax-qualified accounts, or increasing or decreasing amounts held in savings accounts or other liquid investments. See Item 10 for conflicts of interest that arise as a result of the potential for compensation if the Client chooses to accept such recommendations that involve purchasing securities or insurance products from a Representative that is acting as an insurance agent or registered Representative of a broker-dealer.
10 3. Institutional & Other Consulting Services Advisor provides a range of institutional and other consulting services addressing a variety of investment and non-investment matters, such as pension plan administration, investment banking consultation, and other focused investment consultations. The scope of these project-based services varies, as each engagement is individually negotiated and tailored to accommodate the specific needs of a particular Client.
In these cases, the services TPWA provides will be included in a consulting agreement negotiated between TPWA and the Client. TPWA will charge a project or consulting fee, which will vary depending on the nature, complexity, and scope of the services to be provided, as well as other factors, such as the identity of the Client, potential for new or additional assets or referrals, and other factors such to our discretion. Advice is based on objectives communicated, either orally or in writing, by the Client or the Client's advisers. Advice may be provided through individual consultations or a written plan document, as agreed between Advisor and Client.
4. Educational Courses and Seminars Representatives may organize and present, with the firm's prior approval, educational courses and seminars, and will be permitted to collect reasonable fees for such services and related materials. TPWA will monitor any advisory activities of the Representatives in connection with these educational seminars and courses. The Representatives will (i) insure the security and confidentiality of customer records and information; (ii) protect against any anticipated threats or hazards to the security or integrity of customer records and information; and (iii) protect against unauthorized access to or use of customer records or information that could result in substantial harm or inconvenience to any customer. C. Information Regarding Our Services Changes in Client Circumstances Clients are advised that changes in their personal or financial situation, investment objectives, tolerance for risk, investment time horizon, or other Suitability Information may cause a Portfolio, Extended Portfolio, or strategy to become no longer suitable. In the event of any material change in Client's personal or financial circumstances, Client should contact the Representative or TPWA promptly so that we may assist in identifying another Portfolio, Extended Portfolio, program, strategy or other investments that better meet the Client's needs.
Deposit Cash or Cash Equivalents; Excluded Assets Generally, for the IM Program, Client is expected to deliver only cash or cash equivalents to the Custodian; Client may transfer securities to the Custodian, but the securities will be liquidated to cash as soon as reasonably practical, unless we agree otherwise, in our sole discretion. Client may not transfer or deposit to the account any securities that are not publicly traded or that cannot be promptly sold, except upon our express written agreement. Even when we agree such assets may be held in the Managed Account, we shall require such assets to be treated as "Excluded Assets" and for reporting purposes only and for which we shall not have any responsibility to provide advice or manage whatsoever, unless we specifically agree they shall be treated as Assets. Client will grant us and the Custodian the authority, in our respective discretion, to liquidate securities transferred into the Managed Account or to require Client to transfer such securities out of the Managed Account upon request.
Clients may withdraw Assets on notice to TPWA, subject to the usual and customary securities settlement procedures; provided, the Third-Party Programs will have separate procedures and limitations applicable to withdrawals from their program. If Client provides TPWA advance notice of a withdrawal in excess of $10,000 during a Fee Calculation Period, TPWA will provide a pro-rata refund of any unearned, prepaid Advisory Fees (but not Platform Fees, unless TPWA receives a corresponding credit of any Platform Fees it is charged with 11 respect to such Assets by its third-party service providers) received with respect to such Assets based on the remaining number of days in such Fee Calculation Period; provided, such refund shall be in the form of a credit against the next Fee Calculation Period's Advisory Fees. TPWA designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a Client's investment objectives. TPWA may consult with its Clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and tax ramifications, for example.
Differences among Advisory Groups' and Representatives' Accounts For the IM Program, Each of the Advisory Groups and Representatives develop different model Portfolios,, and Extended Portfolios and follow different investment strategies and styles, and have different policies and practices for developing, rebalancing, and adjusting the Portfolios, and Extended Portfolio of their Clients. Consequently, it is expected that the Portfolio and Extended Portfolio levels of volatility, fees, expenses, returns, and performance will vary significantly among accounts from one Representative to another, as well as among TPWA's Advisory Groups and Representatives.
As the registered investment advisor, each Representative acts on TPWA's behalf in providing advisory services; discretion granted by the Client to a Representative will be deemed to be granted to, and may be exercised by, TPWA. TPWA has the authority to direct any act of the Representative in the performance of any service. Although the Representatives act under TPWA's general supervision and TPWA monitors the Representative's accounts, Advisor does not direct or mandate the investment strategy or style of a Representative.
Management of Account Until We Receive Notice Unless and until the Client notifies TPWA in writing to designate a different Portfolio, or Extended Portfolio for their Account, notifies TPWA of material changes in their Suitability Information, or notifies TPWA to impose reasonable restrictions on the investment of their Account, TPWA will continue to manage the Account according to the Suitability Information in TPWA's records. Clients should inform TPWA promptly in writing of significant changes in their individual or family circumstances or financial situation, or in the investment goals or objectives, investment time horizon, tolerance for risk or volatility, or liquidity needs of the Account so that appropriate changes can be made. Such notices must be written.
D. Assets under Management As of December 31, 2023, TPWA managed $1,240,700,489 of Client assets on a discretionary basis.