A. General Description of Advisory Firm.
Treasure Coast Financial Planning, Inc. (“TCFP,” “Firm,” or “we/us/our”) is a registered
investment adviser with the U.S. Securities and Exchange Commission (“SEC”). SEC
registration does not imply a certain level of skill or training. Our Firm was founded in 1996
and became an SEC registered investment adviser in 2013. We are located in Vero Beach,
Florida.
We provide comprehensive wealth management services, which include fee-based asset
management and financial planning investment advisory services to separately managed Client
accounts, primarily on a discretionary basis (“Clients” or “you/your").
Our Firm is organized as a corporation and our principal owner is Guy L. Bassini.
B. Description of Advisory Services
It is our goal to attempt to eliminate, mitigate, or disclose conflicts of interest with our Clients
wherever possible. Our Firm is independent and was structured to avoid the common conflicts
of interest that can exist in the investment advisory business. As further described below, we
do not have any affiliated entities (such as a broker-dealer), proprietary products, investment
banking relationships or other business activities that may be inconsistent with our Client’s
needs. All conflicts of interest are disclosed in this brochure and the brochure supplements. In
addition, as part of our Firm’s compliance program, we have developed procedures to
reasonably identify, mitigate and disclose conflicts of interests for our Firm and our employees.
Our advisory services encompass an assessment of the Client's goals, financial situation, risk
tolerance and time horizon followed by asset allocation, investment selection and investment
implementation recommendations as agreed upon with our Client. We strive to meet with our
Clients to review their investments at least annually and more often as necessary to help them
meet their goals.
We provide investment consulting services that relate to matters such as asset allocation,
executive compensation packages, stock option analysis, business transfer and other general
economic and financial topics. Our consulting services include client retirement plans such as
401(k) and 403(b) plans. For example, some Clients will utilize our services to manage their
retirement plan’s underlying investment allocations. We receive financial planning fees for our
consulting services.
Client account supervision is guided by the stated objectives of our Client’s Investment
Management Agreement (“IMA”) with us, and all Client accounts will be maintained with an
independent custodian bank or broker-dealer.
We participate in the institutional services program offered to independent investment advisers
by Pershing Advisor Solutions LLC (an affiliate of the Bank of New York Mellon) (“Pershing”
or “Platform Provider”). We have selected Pershing because we believe they are one of the
leading custody, clearing, and trade execution providers in the industry. Pershing gives us
access to a comprehensive range of products, and we believe it will help us in our attempt to
observe industry best practices for your account. See Item 12 below for information on our
brokerage practices.
Clients with variable annuity products may select to use our services to manage the subaccount
investments. We will review the annuity’s subaccount options and determine the best fit for
the Client based upon the Client’s investment objectives for the product. Clients that select this
service option will have the annuity’s assets included in the Client’s total assets under
management with our Firm, and management fees will apply.
We also provide tax-related services to Clients. This is not considered an investment advisory
service, and tax-related services make up a small percentage of our overall business.
Additional information regarding our other business activities is disclosed below in
Item 10
and in our Form ADV Part 2B Brochure Supplements for our investment professionals.
At times, TCFP provides educational seminars for Clients and prospective clients. The
seminars are not designed to provide specific and/or personal financial advice, and no fee is
charged.
IRA Rollover Recommendations
For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE
2020-02") when 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 an exemption that requires us to act in your best interest and not
put our interest ahead of yours. Under this exemption, 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.
Donor Advised Fund Services
Some TCFP Clients will establish donor advised funds through various third-party charitable
programs including the American Endowment Foundation (“AEF” or “Charitable Platform”).
Currently, TCFP maintains a relationship with AEF, but does not have a formal referral
arrangement in place with any donor advised fund and does not receive compensation for
referrals to AEF or any other donor advised fund. The funds will be managed in accordance
with the specific investment policies and guidelines of the Charitable Platform. Clients will
establish a donor advised account, transfer funds earmarked for charitable donation and
recognize a tax deduction in the year that funds are transferred into an account opened on the
Charitable Platform. The funds remain in such account until the Client designates a charity, an
amount, and a date to donate to such charity.
Under independent advisor programs established within the Charitable Platform, donors
appoint an independent investment adviser, which could include TCFP, to manage accounts
established on the Charitable Platforms. If appointed, TCFP will manage the donor’s account
pursuant to investment guidelines established by the Charitable Platform.
C. Availability of Tailored Services for Individual Clients
As a Client, you may impose restrictions on investing in certain securities.
The advice we provide is based on the individual needs of each Client, and we are responsible
for all day-to-day investment and trading decisions for accounts. In providing these services,
we consider such factors as size of the account, Client’s income and investment objectives
(including tax sensitivity), investment guidelines, investment restrictions and relative tolerance
for risk as stated in your IMA.
D. Wrap Fee Programs.
This is not applicable as we do not offer any wrap fee programs.
E. Client Assets Under Management.
As of December 31, 2023, we have $193,731,695 in assets under management, managed on a
discretionary basis and $0 managed on a non-discretionary basis.