A. Firm Information
The Patten Group, Inc. (“TPG” or the “Advisor”) is a registered investment advisor with the U.S. Securities and
Exchange Commission (“SEC”). The Advisor is organized as a corporation under the laws of the State of
Tennessee. TPG was founded in March 2014 and is owned and operated by Ashlee B. Patten (Chief Executive
Officer). This Disclosure Brochure provides information regarding the qualifications, business practices and the
advisory services provided by TPG.
B. Advisory Services Offered
TPG provides investment advisory services to individuals, high net worth individuals, families, trusts, estates,
retirement plans, endowments, foundations, charitable organizations, corporations and small businesses (each
referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, which means the Advisor has a fundamental obligation to act and to
provide investment advice in the best interests of Clients. As a fiduciary the Advisor upholds a duty of loyalty,
fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. TPG’s fiduciary
commitment is further described in the Advisor’s Code of Ethics. For more information regarding our Code of
Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.
Wealth Management Services
TPG provides Clients with customized wealth advisory solutions and tailors its advisory services to the individual
needs of the Client based on the goals, risk and return objectives, size and complexity of the Client’s financial
situation. As part of the Advisor’s comprehensive wealth management solutions, the Advisor may provide
financial planning services in addition to investment management services.
Investment Management Services – TPG provides customized investment advisory solutions to its Clients either
as a component of wealth management or pursuant to a stand-alone investment management agreement.
Typically, Clients engage TPG for investment management services on a discretionary basis. Discretionary
management is a form of investment management where decisions to buy and/or sell securities in a Client’s
portfolio are made without Client consent for each transaction. On a limited basis, the Advisor may accept
investment management relationships on a non-discretionary basis.
TPG seeks to ensure that client portfolios are managed in a manner consistent with their respective investment
profiles. TPG consults with the Client at first signing of the investment management agreement during the
initial onboarding process as well as on a continuous basis to determine the Client’s specific risk tolerance, time
horizon, liquidity constraints and other qualitative factors relevant to the management of the Client’s portfolio.
Clients are advised to promptly notify the Advisor if there are any changes in their financial situation or if they
wish to place any limitations on the management of their portfolios. Clients may impose reasonable
restrictions or mandates on the management of their account[s] if TPG determines, in its sole discretion, the
conditions would not materially affect the performance of a management strategy or prove overly burdensome
to the Advisor’s management efforts.
TPG typically constructs investment portfolios utilizing individual equity securities, individual fixed income
securities, mutual funds, exchange traded funds (“ETFs”) and options. TPG may utilize other types of
investments as appropriate for a particular Client. In some cases, the Advisor opts to retain certain legacy
investments based on portfolio fit and/or tax considerations. Any restrictions or mandates imposed by the
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Client and accepted by the Advisor will be serviced on a case-by-case basis that may necessitate labeling these
as directed holdings (as directed by the Client) or asking the Client to sign an additional non-discretionary
agreement for those particular holdings.
In addition, TPG may utilize various investment models for Client portfolios depending on their financial
circumstances and investment needs. The models will utilize the same types of securities that are used in
constructing custom Client investment portfolios.
TPG advises Clients on certain investment products that are not maintained at the primary Custodian, such as
assets included in an employer-sponsored retirement plan (i.e. 401k plans and 403(b) plans), qualified tuition
plan (i.e. 529 plans), variable life insurance, annuity products and/or certain private placement investments.
For these held-away assets TPG directs or recommends the allocation of Client assets among the available
investment options. The Advisor will typically have the discretionary authority to place trades, rebalance and
allocate contributions within these accounts, with the exception of the private placement investments (where
discretion remains with the Client at all times). The Advisor holds Client login credentials for many of these
held-away assets. As such, TPG is deemed to have custody of these assets. Please see Item 15 – Custody for
additional information.
TPG also provides investment advisory services to some Clients on specified held-away private placement
investments. While in many instances TPG did not originally recommend that Clients make these investments,
under the Client’s Investment Management Agreement, TPG provides asset allocation recommendations to the
Client in relation to these private placements in order to provide such Clients with observations and advice
about how these holdings may continue to fit within the Client’s portfolio. TPG is also available for
administrative assistance and provides consolidated reporting on these investments. TPG does not have any
discretion over, nor is it deemed to have custody of, the held-away private placement investments described in
this section.
TPG’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held less than one year to meet the objectives of the Client or due to market conditions. TPG
will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances and
risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on
the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
TPG evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Trading client portfolios occurs for strategic and/or tactical reasons. Portfolio positions may
be rebalanced to more appropriately diversify risk or lower the security concentration of certain positions.
Conversely, TPG may recommend specific positions to increase sector or asset class weightings. The Advisor
may recommend employing cash positions as a hedge against market volatility that could adversely affect the
portfolio. TPG may recommend selling positions for reasons that include, but are not limited to: (i) harvesting
capital gains or losses, (ii) mitigating business or sector risk exposures to a specific security or class of securities,
(iii) adjusting overvaluation or overweighting of the position[s] in the portfolio, (iv) accommodating changes in
risk tolerance of the Client, (v) generating cash to meet Client needs (vi) or responding to any risk deemed
unacceptable for the Client’s risk tolerance.
All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the terms of
the advisory agreement. Please see item 12 – Brokerage Practices.
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Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor serves as a fiduciary by definition of Title I of
the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as
applicable. The aforementioned laws govern retirement accounts. When deemed to be in the Client’s best
interest, the Advisor will provide investment advice
to a Client regarding a distribution from an ERISA
retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers
from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another
account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of
interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No
Client is under any obligation to roll over a retirement account to an account managed by the Advisor.
Use of Independent Managers - TPG has the ability and maintains the option to recommend that Clients utilize
one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”)
for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. The Client may
be required to authorize and enter into an investment management agreement with the Independent
Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. The Advisor
will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the
strategy remains aligned with Clients’ investment objectives and overall best interests. The Advisor will also
assist the Client in the development of the initial policy recommendations and managing the ongoing Client
relationship. The Client, prior to entering into an agreement with an Independent Manager, will be provided
with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the
appropriate disclosures).
Financial Planning and Consulting Services -TPG offers a variety of financial planning services to individuals and
families depending on the Client’s financial situation, goals and objectives. Financial planning and consulting
services are offered either as a component of wealth management or pursuant to a stand-alone financial
planning agreement. Determination of goals and objectives is based on consultation with the Client and the
comprehensiveness of the supporting documents provided by the Client. Financial planning may encompass
one or more areas of need, including but not limited to: (i) investment planning, (ii) retirement planning, (iii)
budget planning, (iv) budget development, (v) personal savings, (vi) education savings and (vii) other areas of
financial problem solving.
TPG offers a comprehensive range of financial planning and consulting services, which include:
• Multi-Generational Wealth Transfer
• Estate Planning Review
• Risk Management Review
• Employee Stock Ownership Plans
• College Funding
• Charitable Giving and Philanthropy
• Advice on Credit Sourcing and/or Debt Paydown & Consolidation
A financial plan or financial consultation prepared for the Client can include either general recommendations
for a course of activity, specific actions to be taken by the Client, or both. For example, recommendations may
be made that the Client start or revise their investment programs, commence or alter retirement savings,
establish education savings and/or establish charitable giving programs. TPG may also refer Clients to an
accountant, attorney or other specialist, as appropriate, for their unique situation. For certain financial
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planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations
and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written
summary. Stand-alone plans or consultations are typically completed within six months of the contract date,
assuming all information and documents requested are promptly provided.
Financial planning and consulting recommendations pose a conflict of interest between the Advisor and the
Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment
management services or to increase the level of investment assets with the Advisor, as it would increase the
amount of advisory fees paid to the Advisor. 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 implement the transaction
through the Advisor.
Reporting-only Services for Purposes of Consolidated Reporting
TPG offers and provides some Clients with reporting-only services. These services include periodic reporting on
Client accounts or assets that are not deemed assets under management with TPG. These periodic reports
detail the performance, asset allocation and/or holdings mix. TPG receives its information and market values
from account custodians, tax accountants, independent managers and other third parties. TPG will consider
the asset classes of investments that are not managed by the Advisor for asset allocation purposes and will
report the performance of those investments relative to an appropriate benchmark, but will not otherwise
provide due diligence or monitoring services on such assets. The inclusion of outside investments in
performance reports does not constitute investment advice, a recommendation or an endorsement by TPG. To
the extent that erroneous information is provided due to inaccurate data from a third party, the Advisor is not
responsible for any inaccuracies that are contained in the report.
Retirement Plan Advisory Services
TPG provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the
company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan
Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is
customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Education & Enrollment Assistance in conjunction with the Plan Administrator
• Investment Policy Statement (“IPS”) Preparation
• Discretionary Investment Management (ERISA 3(38))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• Benchmarking
These services are provided by TPG serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan
Sponsor is provided with a written description of TPG’s fiduciary status, the specific services to be rendered and
all direct and indirect compensation the Advisor reasonably expects under the engagement.
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C. Client Account Management
Prior to engaging TPG to provide investment management services, each Client is required to enter into one or
more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the
Advisor and the Client. These services may include:
• Establishing an Investment Strategy – TPG, in conjunction with the Client, will develop a strategy that
seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – TPG will develop a strategic asset allocation targeted to meet the investment
objectives, time horizon, financial situation and risk tolerance for each Client.
• Portfolio Construction – TPG will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
• Investment Management and Supervision – TPG will provide investment management and ongoing
oversight of the Client’s investment portfolio in order to meet the goals and objectives of the Client.
D. Wrap Fee Programs
TPG does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by TPG.
E. Assets Under Management
As of December 31, 2022, TPG manages $450,467,120 in Client assets, $447,467,815 of which are managed on
a discretionary basis. Clients may request more current information at any time by contacting the Advisor.