tru Independence Asset Management provides investment advice under the name of YellowWood Wealth
Solutions. Hereafter, YellowWood Wealth Solutions, LLC may also be referred to as (“YellowWood” or “the
Firm”) with any descriptions of services, investment processes, fees and other similar items being specific
to YellowWood unless otherwise noted.
TIAM has been registered as an investment adviser since 2014 and is owned by tru Independence, LLC. tru
Independence, LLC, is primarily owned by Craig Stuvland with a minority ownership by Entwood Holdings
LLC, which is owned by David Beatty.
The YellowWood Wrap Program (the “Program”) is an investment advisory program sponsored by
Yellowwood Wealth. Prior to the Firm rendering any of the foregoing advisory services, clients are
required to enter into one or more written agreements with the Firm setting forth the relevant terms and
conditions of the advisory relationship (the “Advisory Agreement”).
As a registered investment adviser YellowWood is a fiduciary to the firm’s investment advisory clients and
has an obligation to act in good faith, and in the best interest of the client and to place the client's interests
first and foremost. This would include a duty of care, which requires among other things for advisers to
ensure that its investment advice is suitable based on the client’s investment profile or mandate. As part of
a duty of loyalty to clients’ advisers must also attempt to eliminate or make full and fair disclosure of all
material facts of any conflicts of interest so a client, or prospective client, can make an informed decision in
each particular circumstance. The structure of the Program and other internal controls described in this
brochure are designed to support the Firm’s ongoing efforts to fulfill its fiduciary duties. This includes actions
to either avoid or mitigate material conflicts of interest which may exist between the Firm and its clients,
and to provide clients with required disclosure of these conflicts of interest. Clients and prospective clients
should carefully consider the information set forth in this Brochure in evaluating the Program. The Firm’s
Financial Advisors (each, a “Financial Advisor,” and collectively, “Financial Advisors”) serve as the primary
point of contact for Program clients. Clients are encouraged to carefully read this Brochure in its entirety and
contact their Financial Advisor with any questions.
While this brochure generally describes the business of the Firm, certain sections also discuss the activities
of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons
occupying a similar status or performing similar functions), employees or any other person who provides
investment advice on the Firm’s behalf and is subject to the Firm’s supervision or control.
The information included in this Brochure is current as of the date of this Brochure and is subject to change
at the Firm’s discretion. Please retain this Brochure for your records.
Assets Under Management
As of December 31, 2023, TIAM managed approximately $543,886,653 in assets for approximately 1139
accounts on a discretionary basis and approximately $13,339,061 in assets for approximately 76 accounts on
a non-discretionary basis. In total, TIAM managed approximately $557,225,714 in assets for approximately
1215 accounts. YellowWood Wealth’s business model managed approximately $191,925,483 in assets for 807
accounts which are managed on a discretionary basis and approximately $13,339,061 in assets for 76 accounts
which are managed on a non-discretionary basis. In total, YellowWood Wealth Management managed
approximately $205,264,544 for approximately 883 accounts, of which approximately $196,458,902 for
approximately 800 accounts are Wrap accounts.
Advisory Services Offered
The Firm offers discretionary investment management, investment advisory services and financial
planning. Prior to the Firm rendering any of the foregoing advisory services, clients are required to enter
into one or more written agreements with the Firm setting forth the relevant terms and conditions of the
advisory relationship (the “Advisory Agreement”).
Investment Management Services
YellowWood offers continuous and regular investment supervisory services on a discretionary basis. We
work with clients and have the ongoing responsibility to select and/or make recommendations based
upon the objectives of the client, as to specific securities or other investments that he/she recommends
or purchases/sells in clients’ accounts. We utilize a variety of investment types when making investment
recommendations/purchases in client accounts which include, but are not limited to equity securities,
fixed income securities, alternatives, and mutual funds. The investments recommended/purchased are
based off of the clients’ individual needs, goals, and objectives. The Firm offers investment advice on any
investment held by the client at the start of the advisory relationship. Financial Planning may be provided
to clients as a part of the Investment Management Services. When being provided as a separate service it
is described in this section under Financial Consulting Services below.
Clients are advised to promptly notify YellowWood if there are 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 if the Firm determines, in its sole discretion, the conditions
would not materially impact the performance of a management strategy or prove overly burdensome to
the Firm’s management efforts.
As stated, investment management is provided on a discretionary basis, in which a client appoints and
authorizes the Firm or a third-party to make investment decisions with respect to the assets in the client’s
account (including authority to buy, sell, or hold securities).
Financial Planning Services
Our Financial Planning Services Service offers clients the ability to have their investment portfolio
allocated among different financial institutions and reviewed by an Investment Adviser Representative for
a negotiated fee. This consultation offers the client a detailed look at their financial condition in relation
to their investment objectives, risk tolerance, time horizon, and any financial goals that they may be
seeking to achieve. This Financial Consultation Service offered by us may or may not be in conjunction
with one of our other fee-based programs.
The Firm provides a variety of financial consulting services to individuals, families, and other clients
regarding the management of their financial resources based upon an analysis of client’s current situation,
goals, and objectives. Consulting encompasses one or more of the following areas: Investment Planning,
Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal
Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis,
Insurance Analysis, Lines of Credit Evaluation, Business and Personal Financial Planning.
While each of these services is available on a stand-alone basis, certain of them may also be rendered in
conjunction with investment portfolio management as part of a comprehensive wealth management
engagement (described in more detail below).
In performing these services, the Firm is not required to verify any information received from the client
or from the client’s other professionals (e.g., attorneys, accounts, etc.) and is expressly authorized to rely
on such information. The Firm may recommend clients engage the Firm for additional related services, its
Supervised Persons in their individual capacities as insurance agents or register representatives of a
broker-dealer and/or other professionals to implement its recommendations. Clients are advised that a
conflict of interest exists if client engages Firm or its affiliates to provide additional services for
compensation. Clients retain absolute discretion over all decisions regarding implementation and are
under no obligation to act upon any of the recommendations made by the Firm under a financial planning
or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the
Firm of any change in their financial situation or investment objectives for the purpose of reviewing,
evaluating, or revising the Firm’s recommendations and/or services.
Use of Independent Managers
YellowWood may select certain Independent Managers or Sub-Advisors to actively manage a portion of
its clients’ assets. The specific terms and conditions under which a client engages an Independent
Manager will be set forth in a separate written agreement with the designated Independent Manager. In
addition to this brochure, clients may also receive the written disclosure documents of the respective
Independent Managers engaged to manage their assets.
The Firm evaluates a variety of information about Independent Managers, which may include the
Independent Managers’ public disclosure documents, materials supplied by the Independent Managers
themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks
to assess the Independent Managers’ investment strategies, past performance, and risk results in relation
to its clients’ individual portfolio allocations and risk exposure. The Firm also takes into consideration each
Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing, and
research capabilities, among other factors.
The Firm continues to provide services relative to the discretionary selection of Independent Managers.
On an ongoing basis, the Firm monitors the performance of those accounts being managed by
Independent Manager. The Firm seeks to ensure the Independent Mangers’ strategies and target
allocations remain aligned with its clients’ investment objectives and overall best interests.
Wrap Fee Program
The Program described in this Brochure is provided to clients in a “wrap fee” arrangement. A wrap fee
arrangement is one in which a single fee is charged based on the market value of assets in the client’s
account, rather than on the transactions in the account.
The Program provides clients with the ability to trade in certain investment products without incurring
separate brokerage commissions or transaction charges. A wrap fee program is considered any
arrangement under which clients receive investment advisory services (which may include portfolio
management or advice concerning the selection of other investment advisers) and the execution of client
transactions for a specified fee or fees not based upon transactions in their accounts where the total costs
will generally increase or decrease as a result of the frequency of transactions in the account and the type
of securities purchased.
At the
onset of the Program, clients complete an investor profile describing their individual investment
objectives, liquidity and cash flow needs, time horizon and risk tolerance, as well as any other factors
pertinent to their specific financial situations. After an analysis of the relevant information,
YellowWood assists its clients in developing an appropriate strategy for managing their assets. Clients’
investment portfolios are generally managed on a discretionary basis by the Firm.
Fees for Participating in the Wrap Fee Program
The Program is offered on an asset-based fee basis, meaning participants pay a single annualized fee based
upon assets under management (“Program Fee”) established as a flat fee or a percentage of the market
value of assets in the account as of a particular date rather than on the transactions in the account as in a
commission account where total costs will generally increase or decrease as a result of the frequency of
transactions in the account and they type of securities purchased.
The Wrap Fee covers advisory services related to the program, portfolio management services provided
by third parties, the execution of transactions, custody services, account servicing, reporting and other
services. The specific fee a client will pay is set forth in their Client Agreement.
In establishing the fee applicable to a client’s account, the Advisor will take into consideration the value
of the assets, and the types of assets, being deposited in the account participating in the relevant Program,
frequency of trading, other assets the client or client’s household may have invested with the Firm, and
the nature of the client relationship. In general, not all clients with the same amount of assets will be
charged the same fee in the same Program.
This management fee generally varies between 25 and 200 basis points (0.25% - 2%), depending on the
size and composition of a client’s portfolio and the type of services rendered. The annual fee is prorated
and charged quarterly, in advance, based upon the market value of the assets being managed by the Firm
on the last day of the previous billing period.
You may make additions to and withdrawals from your Assets at any time, subject to our right to terminate
our services. If Assets are deposited or withdrawn after the beginning of a Billing Period, the Investment
Management Fee will be prorated. All withdrawals are subject to customary securities settlement
procedures. We design our portfolios as long-term investments and Asset withdrawals may impair the
achievement of your investment objectives. In the event the advisory agreement is terminated, the fee for
the final billing period is prorated through the effective date of the termination and the outstanding or
unearned portion of the fee is charged or refunded to the client, as appropriate.
Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g.,
held-away assets, accommodation accounts, alternative investments, etc.), the Firm may negotiate a fee
rate that differs from the range set forth above.
Additional Fee Information
As referenced above, a portion of the fees paid to YellowWood are used to cover the securities
brokerage commissions and transactional costs attributed to the management of its clients’ portfolios.
Services provided through the Program may cost clients more or less than purchasing these services
separately. The number of transactions made in clients’ accounts, as well as the commissions charged for
each transaction, determines the relative cost of the Program versus paying for execution on a per
transaction basis and paying a separate fee for advisory services. Therefore, the Firm has an incentive to
place less trades for clients in the Program since the Firm incurs transaction expenses. Fees paid for the
Program may also be higher or lower than fees charged by other sponsors of comparable investment
advisory programs.
The fees not included in the advisory fee for our wrap services are charges imposed directly by a mutual
fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund
management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers,
fees for trades executed at a broker dealer, wire transfer fees and other fees and taxes on brokerage
accounts and securities transactions.
YellowWood has no internal arrangements in place whereby persons recommending the Program are
entitled to receive additional compensation as a result of clients’ participation. A person recommending
the Program will not earn more compensation than he or she would otherwise receive if a client elected
another investment management program.
Payments to Independent Managers
The Firm pays a portion of the total fee received from the client to the Independent Manager, if applicable,
for services provided to the client through the relevant Program. Although the amounts paid to third
parties participating in the Program may be changed from time to time without notice to clients, such
changes will not impact the amount of the fees paid by clients without prior notification to the client. The
range of fees paid to these third parties vary based on factors such as the investment strategy or style of
the relevant manager, and the size of the client’s account.
Direct Fee Debit
Clients generally provide the Firm with the authority to directly debit their accounts for payment of the
investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts,
from which the Firm retains the authority to directly deduct fees, have agreed to send statements to
clients not less than quarterly detailing all account transactions, including any amounts paid to the Firm.
Account Additions and Withdrawals
Clients may make additions to and withdrawals from their account at any time, subject to the Firm’s right
to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right
to liquidate any transferred securities or declines to accept particular securities into a client’s account.
Clients may withdraw account assets on notice to the Firm, subject to the usual and customary securities
settlement procedures. However, the Firm generally designs its portfolios as long-term investments, and
the withdrawal of assets may impair the achievement of a client’s investment objectives. The Firm 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, short-term
redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or
tax ramifications.
Betterment Advisory Services
Betterment for Advisors is a digital wealth management platform generally serving independent
investment advisory firms. Betterment LLC (“Betterment”), a registered investment advisor, serves as sub-
advisor to your clients (“Clients”). MTG LLC, dba Betterment Securities (“Betterment Securities”), a
registered broker-dealer and member of FINRA and the SIPC, serves as broker-dealer and custodian.
The services provided by Betterment include:
• Goal-Based Investment Management: Betterment’s goal-based investment platform allows
advisors and Clients to identify multiple investment goals for each Client, each with specific
portfolio allocations;
• Portfolio Construction Tools: Advisors and Clients have access to a set of portfolio strategies,
each of which is comprised of low-cost, index-tracking exchange-traded funds or mutual funds
(the latter only for advisors who are approved to construct portfolios with Dimensional Fund
Advisors mutual funds), and are able to customize the risk-level for each investment goal;
• Automated Investment Management Services: Betterment’s algorithms automate back-office
tasks such as trading, portfolio management, tax loss harvesting, and account rebalancing;
• Website and Mobile Application: Betterment’s website and mobile application provide a
platform for account access and monitoring and delivery of account documentation and notices;
and
• Advisor Dashboard: Advisors have access to a dashboard for purposes of monitoring and
managing Client accounts.
Betterment Fees and Compensation
Unless you have negotiated a specific fee discount, Betterment charges your clients an asset-based wrap
fee on amounts invested via the Betterment for Advisors platform that is tiered based on the aggregate
balance of all of your firm’s client accounts at Betterment (not including funds held in Betterment
Everyday Cash Reserve). That wrap fee currently ranges from 0.12% to 0.20% of account balances. The
asset-based wrap fee is charged quarterly in arrears. The services included for the wrap fee include all of
the services provided by Betterment and Betterment Securities through the Betterment for Advisors
platform, including advisory services, custody of assets, execution and clearing of transactions, and
account reporting. Betterment collects wrap fees directly from Clients pursuant to
the terms of the sub-advisory agreement between Betterment and each Client. Clients utilizing the
Betterment for Advisors platform may pay a higher aggregate fee than if the advisory, custodial, trade
execution, and other services were purchased separately. Advisors with clients on this pricing structure
typically also pay a fixed monthly fee to Betterment.
If you charge Clients a fee in addition to the Betterment for Advisors platform fee for assets held on the
Betterment for Advisors platform, Betterment will collect both its and your fee from each Client and
remit your portion of the fee directly to you. Clients should be made aware of this arrangement.
Additional information regarding Betterment’s fees and compensation is described in Betterment’s
Form ADV Part 2A.
Other Betterment Services and Potential Conflicts
As part of your relationship with Betterment and Betterment Securities, Betterment may offer you
services intended to help you manage and further develop your business enterprise, such as access to
webinars and advice about using the Betterment for Advisors platform to grow your business. Betterment
may offer different or expanded services in the future. These services could create an incentive for you to
recommend that your clients invest through the Betterment for Advisors platform. This is a potential
conflict given that your interest in recommending Betterment could be influenced by your receipt of
Betterment’s and Betterment Securities’ services to your business. Other potential conflicts may exist
regarding your use of the Betterment for Advisors platform.