We specialize in the following types of services: Asset Management, Financial Planning & Consulting,
and Referrals to Third Party Money Managers.
Our Advisory Firm:
We are dedicated to providing individuals and other types of clients with a wide array of investment
advisory services. We work with each client to select an asset allocation that is aligned with the
client’s unique investment objectives and risk tolerance. Our firm is a limited liability company
formed in the State of Texas. Our firm has been in business since 2006 and registered as an
investment adviser since 2011 and is owned by TLHC, LLC.
Types of Advisory Services We Offer:
Asset Management:
We offer discretionary management of client assets. As a discretionary manager, we have the
authority to make determinations regarding the purchase and sale of securities for clients. Clients
grant us this discretionary authority in our advisory agreement. We work with each client to establish
a mutually accepted asset allocation that is aligned with the client’s unique investment objectives and
risk tolerance. In constructing allocation for clients, we may select from a wide range of available
investment options listed below including our own proprietary investment strategies described
below.
We emphasize continuous and regular account supervision. As part of our asset management service,
we generally create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”),
mutual funds and other public and private securities or investments. The client’s individual investment
strategy may include some or all of the previously mentioned securities or be one of our proprietary
strategies further discussed in Item 8 of this Brochure. Once the appropriate portfolio has been
determined, we review the portfolio at least quarterly and if necessary, rebalance the portfolio based
upon the client’s individual needs, stated goals and objectives.
Financial Planning & Consulting:
We provide a variety of financial planning and consulting services to individuals, families and other
clients regarding the management of their financial resources based upon an analysis of the client’s
current situation, goals, and objectives. Generally, such financial planning services will involve
preparing a financial plan or rendering a financial consultation for clients based on the client’s
financial goals and objectives. This planning or consulting may encompass one or more of the
following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning,
Education Planning, Corporate and Personal Tax Planning (this service does not involve tax or legal
advice), Insurance Analysis, Business and Personal Financial Planning.
Our written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients. For example,
recommendations may be made that the clients begin or revise investment programs, create or revise
wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or
establish education or charitable giving programs. It should also be noted that we refer clients to an
ADV Part 2A – Firm Brochure.ADV2A.2023.03.23 Page 5 TLWM, LLC
accountant, attorney or other specialist, as necessary for non-advisory related services. From time to
time we have received referrals and could receive future referrals from these specialists which could
create a conflict of interest. For written financial planning engagements, we provide our clients with
a written summary of their financial situation, observations, and recommendations. For financial
consulting engagements, we usually do not provide our clients with a written summary of our
observations and recommendations as the process is less formal than our planning service. Plans or
consultations are typically completed within six (6) months of the client signing a contract with us,
assuming that all the information and documents we request from the client are provided to us
promptly. Implementation of the recommendations will be at the discretion of the client, and unless
engaged separately to do so, we will not be responsible for the implementation of the plan. You
assume full responsibility for the implementation of the plan.
LPL Financial Sponsored Advisory Programs:
Our firm may provide advisory services through certain programs sponsored by LPL Financial, LLC
(“LPL Financial”), a registered investment advisor and broker-dealer. Below is a brief description of
each LPL advisory program available to our firm. For more information regarding the LPL programs,
including more information on the advisory services and fees that apply, the types of investments
available in the programs and the potential conflicts of interest presented by the programs please see
the LPL Financial Form ADV Part 2 and the applicable client agreement.
The following advisory services are made available through LPL:
• Manager Access Select (MAS) is a separate account platform available through LPL
Financial, LLC (“LPL Financial”) that offers high net-worth investors the ability to access a
variety of institutional Portfolio Managers at significantly lower account minimums. This
enables clients to enjoy a higher level of specialization and service through the ownership of
individual securities. Advisors can choose from a broad range of Portfolio Managers and
multiple investment styles are available, including equity, fixed income, balanced,
international, ETF, REIT and socially responsible portfolios.
• Manager Access Network (MAN) enables high net worth investors to access a variety of
institutional Portfolio Managers at significantly
lower account minimums. By using separate
account managers, clients can enjoy a higher level of specialization and service through the
ownership of individual securities. A broad range of Portfolio Managers and multiple
investment styles are available, including equity, fixed income, balanced, international, ETF,
REIT and socially responsible portfolios.
• Model Wealth Portfolios Program (MWP) offers clients a professionally managed mutual
fund asset allocation program. Our firm will obtain the necessary financial data from the
client, assist the client in determining the suitability of the MWP program and assist the client
in setting an appropriate investment objective. The Advisor will initiate the steps necessary
to open an MWP account and have discretion to select a model portfolio designed by LPL’s
Research Department consistent with the client’s stated investment objective. LPL’s Research
Department is responsible for selecting the mutual funds within a model portfolio and for
making changes to the mutual funds selected.
The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds
(including in certain circumstances exchange traded funds) and to liquidate previously
purchased securities. The client will also authorize LPL to effect rebalancing for MWP
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accounts. The MWP program makes available model portfolios designed by strategists other
than LPL’s Research Department. The Advisor will have discretion to choose among the
available models designed by LPL and outside strategists.
• Optimum Market Portfolios Program (OMP) offers clients the ability to participate in a
professionally managed asset allocation program using Optimum Funds Class I shares. Under
OMP, client will authorize LPL on a discretionary basis to purchase and sell Optimum Funds
pursuant to investment objectives chosen by the client. We will assist the client in determining
the suitability of OMP for the client and assist the client in setting an appropriate investment
objective. We will have discretion to select a mutual fund asset allocation portfolio designed by
LPL consistent with the client’s investment objective. LPL will have discretion to purchase and
sell Optimum Funds pursuant to the portfolio selected for the client. LPL will also have authority
to rebalance the account.
• Personal Wealth Portfolios Program (PWP) offers clients an asset management account
using asset allocation model portfolios designed by LPL. Advisor will have discretion for
selecting the asset allocation model portfolio based on client’s investment objective. Advisor
will also have discretion for selecting third party money managers (PWP Advisors) or mutual
funds within each asset class of the model portfolio. LPL will act as the overlay portfolio
manager on all PWP accounts and will be authorized to purchase and sell on a discretionary
basis mutual funds and equity and fixed income securities.
Tailoring of Advisory Services:
We offer individualized investment advice to clients utilizing our Asset Management services.
Additionally, we offer general investment advice to clients utilizing our Financial Planning and
Consulting service.
Prior to managing a client’s assets, each new client is provided individualized investment advice,
which is aligned with the client’s level(s) of tolerance for risk, the client’s investment objectives and
the client’s investment time horizon. This individualized investment advice is created for the client
after we receive and review the client’s completed confidential profile or similar document and other
information provided by client, which may include information obtained by notes from or
conversations with client. This information is documented in the client’s file, which is created and
maintained by us. Each client’s investment portfolio is created to meet the specific investment needs
and objectives expressed by the client. Clients with similar investment needs and objectives may have
investment portfolios where the investments and asset categories utilized are similar, or identical, to
investment portfolios for clients with similar, or identical needs and objectives. Furthermore, while
two clients with distinctly different risk level and objectives may have some of the same investments
in their respective portfolios, the percentage holdings of those investments may differ as might the
asset class categories. If some or all of the same asset classes are used for both clients, the percentages
invested in shared asset classes may differ.
We typically do not allow clients to impose restrictions on investing in certain securities or types of
securities who are enrolled in our proprietary investment strategies referenced in Item 8. In the rare
instance that we would allow restrictions, it would be limited to our Asset Management service.
ADV Part 2A – Firm Brochure.ADV2A.2023.03.23 Page 7 TLWM, LLC
Participation in Wrap Fee Programs:
We no longer offer a Wrap Fee Program to new investors, nor do we open any new wrap fee accounts.
We manage certain legacy accounts on a Wrap Fee basis, and these wrap fee and as well as our non-
wrap fee accounts are managed on an individualized basis according to the client’s investment
objectives, financial goals, risk tolerance, etc. We do not manage wrap fee accounts in a different
fashion than non-wrap fee accounts. All clients enrolled in a wrap fee program will receive a copy of
our firm’s ADV 2A Appendix 1 Wrap Fee Program Brochure.
Regulatory Assets Under Management:
As of December 31, 2023, we manag
e1 $484,870,433 on a discretionary basis and $0 on a non-
discretionary basis.