This Disclosure document is being offered by WealthTrust Asset Management, LLC (the “Firm”
or “WTAM”) in connection with the investment services we provide under our three
business channels: Investment Advisory, Asset Management and RIA consulting and
facilitation. It is intended to disclose information about the services we provide and the
manner in which those services are made available.
Our Firm was established in 2014 by John G. McHugh and became a registered investment
adviser in 2015, with principal ownership by John G. McHugh. It is headquartered in Destin,
Florida with branch offices in Plano, Texas and Mobile, Alabama.
Investment Advisory services are performed under the name of TAMP Advisory Solutions
(“TAMP”) which is a dba for the firm. While TAMP may be used interchangeably by our
Investment Advisory division, for simplicity purposes in this brochure, we will use “TAMP”
to refer to our Investment Advisory services.
The Firm’s Asset Management division operates under the name WealthTrust Asset
Management (“WealthTrust”) and offers discretionary model management under the
WealthTrust DBS Portfolios. Our WealthTrust Portfolios are offered to investment advisory
clients of our firm and unaffiliated investment advisors. As of December 31, 2020, our asset
management business channel is our company's primary business in revenue and assets.
The third division of the Firm markets its business under the name of 925 Advisory (“925”).
925 operates as an Advisory Services Platform to investment advisers for asset management
and certain back-office services.
As a registered investment adviser, we act as a fiduciary and it is our duty to always act in
the client’s best interest.
Asset Management Services
Our Firm offers asset management services to unaffiliated registered investment advisers
(hereafter referred to as “Independent RIA”) whereby our Firm manages some or all of
these Independent RIA’s client (“Adviser Client”) assets according to the WealthTrust DBS
Portfolio chosen by the Independent RIA. In these situations, the Adviser Client remains a
client of the Independent RIA. The decision into which investment strategy(s) Adviser Client
assets are invested is based on suitability information gathered and reviewed by the
Independent RIA. Our Firm will manage these assets on a discretionary basis based on its
investment strategies and not based on overall Adviser Client suitability. WealthTrust Asset
Management Services are also offered to Trust Companies, Broker-Dealers, Qualified
Retirement Plans and Family Offices. Management of these outside assets is facilitated
through sub-advisory or tri-party agreements with the Independent RIA and our firm or by
the Independent RIA’s access to the WealthTrust DBS portfolios through managed account
platforms.
Through an Independent RIA’s Sub-Advisory or Tri-Party Agreement with our firm, we will
be given access to the Adviser Client accounts enrolled in our WealthTrust DBS management
services. Our Firm will facilitate all the trading and rebalancing and may perform billing
functions such as the deduction of management fees on behalf of the Independent RIA.
WealthTrust will determine when existing positions will be liquidated to facilitate investing
in our models. Our Firm will not tailor our models to accommodate any limitations or
restrictions in the Adviser Client portfolios, however, accommodations may be approved
for legacy positions on a case-by-case basis. WealthTrust will not have direct contact with
individual Adviser Client, only communication with and direction by the Independent RIA.
Through our agreement with an unaffiliated third-party Technology platform, Orion Advisor
Services, our Firm may provide an online portal for both Adviser Clients and Independent
RIAs. This portal will give access to reporting that details current positions and balances,
asset allocation, transaction history and performance.
Model Portfolio Subscription Services
Our Firm offers WealthTrust DBS model portfolios on 3rd Party digital platforms to which
independent financial institutions, including unaffiliated Registered Investment Advisors,
banks, broker-dealers (“Financial Institutions”), may subscribe. These platforms allow
Independent RIAs access to our Firm’s DBS portfolios as an investment option for their client
accounts. Under this arrangement, our Firm will not be given access to Independent RIAs
client accounts. Our Firm does not enter direct relationships with these clients nor the
Independent RIAs. Instead, our Firm maintains, monitors, and supervises the DBS models
on the subscribing firm’s platform, providing ongoing model updates as well as buy, sell,
and rebalancing recommendations. On occasion, these models can hold slightly different
funds than our direct discretionary asset management accounts due to custodial
relationship constraints that are outside of our control. The Independent RIA Adviser(s) will
be responsible for selecting the DBS model that is suitable for their client. Financial
Institutions maintain their own custodial relationships and offer separate execution and
clearing services. Subscribing firms or Independent RIAs are also responsible for providing
all administrative and performance reporting services to their clients.
Investment Services for Clients of Our Firm
For clients of our Firm, we offer discretionary and non-discretionary investment
management and investment monitoring services for an annual fee based on a percentage
of the Client’s assets under management or a flat dollar amount. A flat dollar Minimum
Annual Investment services fee may also apply. Discretionary asset management services
include investment analysis, ongoing allocation of investments, and monitoring services for
the portfolio. Non-Discretionary investment management will include investment analysis
and recommendations to the Client, with all transactions being authorized by the Client.
Investment Monitoring Services, without investment management, include a periodic
review of the holdings within the account. Monitoring Services may be offered for non-
discretionary accounts and there may be an Investment Services Fee assessed for these
services. Zero Fee accounts, or accounts that are not being assessed a fee for services are
managed by the Client without expectation of analysis, monitoring, or buy/sell
recommendations by the Firm. All client accounts, regardless of services performed, will be
included in Client account reviews with their Investment Advisor Representative.
We help determine our Clients recommended portfolio composition based on their needs,
accepted portfolio restrictions, if any, financial goals, and risk tolerance. We will work with
our Clients to obtain necessary information regarding their financial condition, investment
objectives, liquidity requirements, risk tolerance, time horizons, and any restrictions on
investing. This enables us to determine the asset allocation we view as appropriate for our
Client’s investment objectives and needs.
In performing our services, we shall not be required to verify any information received from
our Clients or from their other professionals. Upon request, we may recommend the
services of other professionals, such as tax attorney’s or accountants, but Clients are under
no obligation to engage the services of any such recommended professional.
For discretionary account management, once we have determined the types of investments
to be included in our Clients portfolio, and allocated them, we will provide ongoing portfolio
review and management services. This approach requires us to review our Clients portfolio
at least quarterly. Under discretionary management, we are authorized to trade and
rebalance the investment account as we deem appropriate, without consultation with the
Client. This includes discretion of all investment decisions and all trades entered.
For non-discretionary accounts, client’s retain control over investment decisions. While we
may render investment advice and recommendations, all investment decisions will be made
by the Client. No purchase, sale, or other transaction(s) will be made with respect to any
security or other assets in the Account without the Client’s authorization. It is at the
discretion of the client as to whether to follow, or not to follow the investment advice
provided by the Firm.
Clients will have the ability to leave standing instructions with us to refrain from investing
in particular industries or invest in limited amounts of securities, including socially conscious
investment preferences or restrictions. We will try, as much as possible, to accommodate
these requests, but such requests are not guaranteed to be honored. It should be
understood that investment in certain securities such as mutual funds or Exchange Traded
Funds (“ETFs”) may make it impossible for us to ensure that a client’s portfolio will not invest
in a particular industry or security. Account holders have a direct and beneficial interest in
their securities, rather than an undivided interest in a pool of securities.
Clients of our Firm are advised and are expected to understand that our past performance
is not a guarantee of future results. Certain market and economic risks exist that may
adversely affect an account’s performance and result in capital losses. We do not guarantee
the results of asset management performed or consulting advice we give, including the
performance of our WealthTrust Asset Management DBS portfolios. Thus, significant losses
can occur by using our services.
We may offer an initial complimentary meeting with our clients; however, investment
advisory services are initiated only after our Clients and the Firm execute a Client
Engagement Agreement.
Clients may also engage WTAM to manage and/or advise on certain investment products
that are not maintained at their primary custodian, such as variable life insurance and
annuity contracts. In these situations, WTAM will direct or make recommendations for the
allocation of
client assets among the various investment options available with the product.
These assets are generally maintained at the underwriting insurance company or custodian
and clients retain responsibility for effecting trades in these accounts. For these services
WTAM will charge no more than 1% of AUM and require a signed client agreement.
Retirement Plan Investment Advisory Services
Retirement Plan Advisory Services consists of assisting employer plan sponsors establish,
monitor and review their company's retirement plan. As the needs of the plan sponsor dictate,
areas of advising could include investment selection and monitoring, plan structure, and
participant education.
We will help evaluate our Clients plan’s needs and objectives through an initial meeting to
collect data, review plan information, and assist our Clients in developing or updating the
plan’s provisions. Ongoing services to our Clients may include recommendations regarding
the selection and review of unaffiliated mutual funds that, in our judgment, are suitable for
plan assets for our Clients to be invested. We periodically review the investment options our
Clients select and make recommendations to keep or replace plan investment options as
appropriate. We perform a comprehensive review of potential service providers or vendors
and will assist our Clients with converting from their incumbent service provider to a new
service provider they select. Our Clients are under no obligation to follow the
recommendations we make.
Services available under a Client Engagement Agreement permit us to provide financial
education to our Clients’ plan participants. The scope of education provided to participants
at our Clients request will not constitute “investment advice” within the meaning of ERISA
and participant education will relate to general principles for investing and information
about the investment options currently in the plan. We may also participate in initial
enrollment meetings and periodic workshops and enrollment meetings for new participants
as we agree upon.
All Retirement Plan Advisory Services shall be in compliance with any applicable Federal and
State law(s) regulating the services provided by our Agreement. This section applies to an
Account that is a pension or other employee benefit plan (a “Plan”) governed by the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). If our Clients Account is part of
a Plan and we accept appointments to provide our services to our Clients Account, we
acknowledge that we are a fiduciary within the meaning of Section 3(21) of ERISA (but only with
respect to the provision of services described in section 1 of this agreement). Our Clients
represent that (i) Our appointment and services are consistent with the Plan documents, (ii)
Our Clients have furnished us true and complete copies of all documents establishing and
governing the Plan and evidencing their authority to retain our firm. Our Clients further
represent that they will promptly furnish us with any amendments to the Plan, and agree that,
if any amendment affects our rights or obligations, such amendment will be binding on us only
with our prior written consent. If our Clients Account contains only a part of the assets of the
Plan, they understand that we will have no responsibilities for the diversification of the Plan’s
investments, and we have no duty, responsibility or liability for the assets that are not in the
account. If ERISA or other applicable law requires bonding with respect to the assets in our
Client’s account, they will obtain and maintain at their expense bonding that satisfies this
requirement and covers the Firm and any of our affiliates.
Financial Planning Services
Financial advisory services provided by us to our Clients may include the analysis of their
situation and assistance in identifying and implementing appropriate financial planning and
investment management techniques to help the client meet their specific financial
objectives. Such service may include a written financial analysis and specific or general
investment and/or planning recommendations. Financial Plans offered by the Firm and its
IARs have a focus on long term investment planning.
In preparing our Clients financial plan, we may address any or all of the six areas of financial
planning established by the National Endowment for Financial Education and endorsed by
the Certified Financial Planner Board of Standards, depending on our Clients specific needs.
These include financial position, protection planning, investment planning, income tax
planning, retirement planning, and estate planning.
Our specific services in preparing our Client’s plan may include:
• Review and clarification of our Client’s financial goals.
• Assessment of our Clients overall financial position including cash flow, balance
sheet, investment strategy, risk management and estate planning.
• Create of a unique plan for each goal our Clients have including personal and
business real estate, education, retirement or financial independence, charitable
giving, estate planning, business succession and other personal goals.
• Develop of a goal-oriented investment plan around tax suggestions, asset allocation,
expenses, risk and liquidity factors for each goal. This includes IRA and qualified
plans, taxable and trust accounts that require special attention.
• Design a complete risk management plan including risk tolerance, risk avoidance,
mitigation and transfer, including liquidity as well as various insurance and possible
company benefits.
• Craft and implement, in conjunction with our Clients estate and/or corporate
attorneys as tax advisor, an estate plan to provide for our Clients and/or our Clients’
heirs in the event of an incapacity or death.
We also provide clients investment advice on a more limited basis on one or more isolated
areas of concern such as estate planning, retirement planning, or any other specific topic.
Additionally, we may provide advice on non-securities matters in connection with the
rendering of estate planning, insurance, and/or annuity advice.
Our Investment Advisor Representatives with Branded Practices
Your IAR may market their practice under one of our firm’s dba names, TAMP Advisory
Solutions. In addition, some of our firm’s IARs have branded their practices with their own
independent legal business entity name. The Client should understand that the independent
businesses are legal entities of the IAR and not of our firm. However, regardless of the name
under which our IAR markets their practice, all of our IARs are under the supervision of our
firm and their advisory services are provided through our firm. A complete listing of these
entities is listed on our ADV Part 1.
Pricing Structure for Investment Services (Wrap and Non-Wrap)
Wrap Accounts – The investment services fee stated in the Client Engagement
Agreement includes the investment services and all transaction costs.
Non-Wrap Accounts – The investment services fee stated in the Client Engagement
Agreement covers the investment services only. Transaction costs will be billed by
the custodian in addition to the investment services fee.
Prior to 10/1/2021, services to our clients were offered under a “wrap” or “non-wrap”
pricing structure.
However, in an effort for transparency of charges incurred in a Client’s account, effective
10/1/21 our firm began phasing out our wrap fee program. And, as a result, all new Client
accounts are priced on a “Non-Wrap” basis. Non-Wrap pricing allows the fee stated in the
Client Engagement agreement to solely encompass Investment Advisory and Asset
Management services provided by our firm. Any transaction costs are charged directly to
the Client account by the Custodian.
Clients with legacy accounts that are priced under our wrap fee program are encouraged to
change to non-wrap pricing. Because this change in pricing may result in additional costs to
the Client, these costs should be reviewed by the Client and their Investment Advisor
Representative.
Wrap and Non-Wrap designations refer to the pricing structure of a Client account and have
no bearing on the investment services provided to those accounts by the Firm. Our Firm
does not manage wrap fee accounts in a different fashion than non-wrap fee accounts.
Details of our Firm’s legacy Wrap Fee Program are contained in the firm’s ADV 2A Wrap
Program Brochure.
Written Acknowledgement of Fiduciary Status
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 a special rule that requires us to act in
your best interest and not put our interest ahead of yours. Under this special rule’s
provisions, 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.
Assets
Regulatory Assets Under Management (RAUM) - As of December 31, 2023, we have
$ 158,339,606 regulatory assets under discretionary management and
$ 21,672,780 regulatory assets under non-discretionary management.
Assets Under Advisement (AUA) - Our Assets Under Advisement as of December 31, 2023
total $ 97,654,016.