A. Trinity Financial Advisors LLC (the “Registrant”) is an Ohio limited liability company
formed in 2004. The Registrant was previously registered as an investment adviser with
the Ohio Division of Securities and transitioned its registration to the U.S. Securities and
Exchange Commission on April 1, 2015. The Registrant is principally owned by Geoffrey
Biehn, who serves as the President and Chief Compliance Officer. Benjamin Hartings
serves as Vice President and is also a minority owner.
B. As discussed below, the Registrant offers investment advisory services to its clients
(currently: individuals and high net worth individuals), as well as financial planning and
consulting services on a fee-only basis.
INVESTMENT ADVISORY SERVICES
The client can engage the Registrant to provide discretionary investment advisory services
on a fee-only basis. The Registrant’s annual investment advisory fee is based upon a
percentage (%) of the market value of the assets placed under management. Before
engaging the Registrant to provide investment advisory services, clients are required to
enter into an Investment Advisory Agreement with Registrant setting forth the terms and
conditions of the engagement (including termination), describing the scope of the services
to be provided, and the fee that is due from the client.
Registrant’s annual investment advisory fee includes investment advisory services, and
general financial planning and consulting services. In the event that the client requires
extraordinary planning and/or consultation services (to be determined in the sole discretion
of the Registrant), the Registrant may determine to charge for such additional services
pursuant to a stand-alone Financial Planning and Consulting Agreement (see below).
The Registrant provides investment advisory services tailored specifically to the needs of
each client. Before providing investment advisory services, an investment adviser
representative will ascertain each client’s investment objectives. Then, the Registrant will
allocate and/or recommend that the client allocate investment assets consistent with the
designated investment objectives. The Registrant primarily allocates client investment
assets among: exchange-listed securities, mutual funds, individual bonds, bond funds, and
exchange traded funds (“ETFs”) on a discretionary basis in accordance with the client’s
designated investment objective(s). Once allocated, the Registrant provides ongoing
monitoring and review of account performance and asset allocation as compared to client
investment objectives and may periodically rebalance/execute transactions for the account
based upon such reviews.
BUSINESS ADVISORY SERVICES
Registrant also offers combined investment advisory services and business-related
financial planning services to business entities. While the investment advisory services are
generally as described immediately above, the business-related financial planning services
somewhat differ. Before engaging Registrant to provide investment advisory services,
clients are required to enter into an Investment Advisory Agreement with Registrant setting
forth the terms and conditions of the engagement (including termination), describing the
scope of the services to be provided, and the fee that is due from the client. The client and
Registrant will agree on the nature and scope of those financial planning services from time
to time, which will generally include some or all of the following: overall business analysis
and review; cash flow planning; company distribution planning; receivables analysis;
coordination with client’s designated tax professional(s) regarding tax planning; analysis
and advice regarding buying or selling part or an entirety of the client’s business; business
real estate structuring, financing, or refinancing analysis. Registrant will provide these
services as appropriate during the engagement but will not be obligated to provide such
services with any regularity or according to a set schedule unless specifically agreed with
the client.
MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. To the extent requested by the client, Registrant will generally provide financial
planning and related consulting services regarding non-investment related matters, such as
estate planning, tax planning, insurance, etc. Prior to engaging Registrant to provide
planning or consulting services, clients are generally required to enter into a Financial
Planning and Consulting Agreement with Registrant setting forth the terms and conditions
of the engagement (including termination), describing the scope of the services to be
provided, and the portion of the fee that is due from the client prior to Registrant
commencing services. Registrant does not serve as a law firm, accounting firm, or
insurance agency, and no portion of its services should be construed as legal, accounting,
or insurance implementation services. Accordingly, Registrant does not prepare estate
planning documents, tax returns, or sell commissioned insurance products. To the extent
requested by a client, Registrant may recommend the services of other professionals for
certain non-investment implementation purposes (i.e., attorneys, accountants, insurance
agents, etc.). The client is under no obligation to engage those services. The client retains
absolute discretion over all such implementation decisions and is free to accept or reject
any recommendation from Registrant and/or its representatives. The engaged licensed
professional (i.e., attorney, accountant, insurance agent, etc.), and not Trinity, shall be
responsible for the quality and competency of the services provided. If the client engages
any recommended professional on a separate and individual basis, and a dispute arises
thereafter relative to such engagement, the client agrees to seek recourse exclusively from
and against the engaged professional. The preceding sentence shall not limit or waive any
applicable rights under federal or state law, including securities laws and fiduciary
obligations that cannot be limited or waived.
Client Obligations. In performing its services, Registrant shall not be required to verify
any information received from the client or from the client’s other professionals and is
expressly authorized to rely thereon. Moreover, each client is advised that it remains their
responsibility to promptly notify the Registrant if there is ever any change in their financial
situation or investment objectives for the purpose of reviewing, evaluating, or revising
Registrant’s previous recommendations and/or services.
Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the
client’s best interest. Registrant will review client portfolios on an ongoing basis to
determine if any changes are necessary based upon various factors, including, but not
limited to, investment performance, market conditions, fund manager tenure, style drift,
account additions/withdrawals, and/or a change in the client’s investment objective. Based
upon these factors, there may be extended periods of time when Registrant determines that
changes to a client’s portfolio are unnecessary. Clients remain subject to the fees described
in Item 5 below during periods of portfolio inactivity. Of course, as indicated below, there
can be no assurance that investment decisions made by the Registrant will be profitable or
equal any specific performance level(s).
Account Aggregation / Financial Planning Platforms. Registrant may provide its clients
with access to online account aggregation / financial planning platforms (the “Platforms”).
The Platforms can allow a client to view their complete asset allocation, including those
assets that Registrant does not manage (the “Excluded Assets”). Registrant does not
provide investment management, monitoring, or implementation services for the Excluded
Assets. Therefore, Registrant shall not be responsible for the investment performance of
the Excluded Assets. Rather, the client and/or their advisor(s) that maintain management
authority for the Excluded Assets, and not Registrant, shall be exclusively responsible for
such investment performance. The client may choose to engage Registrant to manage some
or all of the Excluded Assets pursuant to the terms and conditions of an Investment
Advisory Agreement between Registrant and the client. The Platforms may also provide
access to other types of information and functionality, including financial planning
information and applications/calculators, which should not, in any manner whatsoever, be
construed as services, advice, or recommendations provided by Registrant. Finally,
Registrant shall not be held responsible for any adverse results a client may experience if
the client engages in financial planning or other functions available on the Platforms
without Registrant’s assistance or oversight.
Reporting Services.
Registrant can also provide account reporting services, which can incorporate client
investment assets that are not part of the assets that Registrant manages (the “Excluded
Assets”). Unless agreed to otherwise, the client and/or his/her/its other advisors that
maintain trading authority, and not Registrant, shall be exclusively responsible for the
investment performance of the Excluded Assets. Unless also agreed to otherwise,
Registrant does not provide investment management, monitoring or implementation
services for the Excluded Assets. If the Registrant is asked to make a recommendation as
to any Excluded Assets, the client is under absolutely no obligation to accept the
recommendation, and Registrant shall not be responsible for any implementation error
(timing, trading, etc.) relative to the Excluded Assets. The client can engage Registrant to
provide investment management services for the Excluded Assets pursuant to the terms
and conditions of the Investment Advisory Agreement between Registrant and the client.
• eMoney and Addepar. In the event that the Registrant provides the client with
access to an unaffiliated vendor’s website such as eMoney or Addepar, and the
site provides access to information and/or concepts, including financial
planning, the client, should not, in any manner whatsoever, infer that such
access is a substitute for services provided by the Registrant. Rather, if the
client utilizes any such content, the client does so separate and independent of
the Registrant.
Other Assets. A client may:
• hold securities that were purchased at the request of the client or acquired prior
to the client’s engagement of the Registrant. Generally, with potential
exceptions, the Registrant does not/would not recommend nor follow such
securities, and absent mitigating tax consequences or client direction to the
contrary, would prefer to liquidate such securities. Please Note: If/when
liquidated, it should not be assumed that the replacement securities purchased
by the Registrant will outperform the liquidated positions. To the contrary,
different types of investments involve varying degrees of risk, and there can be
no assurance that future performance of any specific investment or investment
strategy (including the investments and/or investment strategies recommended
or undertaken by the Registrant) will be profitable or equal any specific
performance level(s). In addition, there may be other securities and/or accounts
owned by the client for which the Registrant does not maintain custodian access
and/or trading authority; and,
• hold other securities and/or own accounts for which the Registrant does not
maintain custodian access and/or trading authority.
Corresponding Services/Fees: When agreed to by the Registrant, the Registrant
shall: (1) remain available to discuss these securities/accounts on an ongoing basis
at the request of the client; (2) monitor these securities/accounts on a regular
basis, including, where applicable, rebalancing with client consent; (3) shall generally
consider these securities as part of the client’s overall asset allocation; (4) report on
such securities/accounts as part of regular reports that may be provided by the
Registrant; and, (5) include the market value of all such securities for purposes of
calculating advisory fee.
Cash Positions. Registrant continues to treat cash as an asset class. As such, unless
determined to the contrary by Registrant, all cash positions (money markets, etc.) shall
continue to be included as part of assets under management for purposes of calculating
Registrant’s advisory fee. At any specific point in time, depending upon perceived or
anticipated market conditions/events (there being no guarantee that such anticipated market
conditions/events will occur), Registrant may maintain cash positions for defensive
purposes. In addition, while assets are maintained in cash, such amounts could miss market
advances. Depending upon current yields, at any point in time, Registrant’s advisory fee
could exceed the interest paid by the client’s money market fund. ANY QUESTIONS:
Registrant’s Chief Compliance Officer, Geoffrey Biehn, remains available to address
any questions that a client or prospective may have regarding the above fee billing
practice.
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from
account transactions or new deposits, be swept to and/or initially maintained in a specific
custodian designated sweep account. The yield on the sweep account will generally be lower
than those available for other money market accounts. When this occurs, to help mitigate
the corresponding yield dispersion, Registrant shall (usually within 30 days thereafter)
generally (with exceptions) purchase a higher yielding money market fund (or other type
security) available on the custodian’s platform, unless Registrant reasonably anticipates that
it will utilize the cash proceeds during the subsequent 30-day period to purchase additional
investments for the client’s account. Exceptions and/or modifications can and will occur
with respect to all or a portion of the cash balances
for various reasons, including, but not
limited to the amount of dispersion between the sweep account and a money market fund,
the size of the cash balance, an indication from the client of an imminent need for such cash,
or the client has a demonstrated history of writing checks from the account. Please Note:
The above does not apply to the cash component maintained within a Registrant actively
managed investment strategy (the cash balances for which shall generally remain in the
custodian designated cash sweep account), an indication from the client of a need for access
to such cash, assets allocated to an unaffiliated investment manager, and cash balances
maintained for fee billing purposes. Please Also Note: The client shall remain exclusively
responsible for yield dispersion/cash balance decisions and corresponding transactions for
cash balances maintained in any Registrant unmanaged accounts. ANY QUESTIONS:
Registrant’s Chief Compliance Officer, Geoffrey Biehn, remains available to address
any questions that a client or prospective client may have regarding the above.
Retirement Plan Rollovers – No Obligation / Conflict of Interest. A client or prospective
client leaving an employer typically has four options regarding an existing retirement plan
(and may engage in a combination of these options): (i) leave the money in the former
employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is
available and rollovers are permitted, (iii) roll over to an Individual Retirement Account
(“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age,
result in adverse tax consequences). If Registrant recommends that a client roll over their
retirement plan assets into an account to be managed by Registrant, such a recommendation
creates a conflict of interest if Registrant will earn new (or increase its current)
compensation as a result of the rollover. If Registrant provides a recommendation as to
whether a client should engage in a rollover or not (whether it is from an employer’s plan
or an existing IRA), Registrant is acting as a fiduciary 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. No client is under any obligation to roll
over retirement plan assets to an account managed by Registrant. The Registrant’s
Chief Compliance Officer, Geoffrey Biehn, remains available to address any questions
regarding the conflict of interest presented by such a rollover recommendation.
Fiduciary Status: Per the DOL: “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.”
Accordingly, relative to retirement accounts, “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.”
Borrowing Against Assets/Risks. A client who has a need to borrow money could
determine to do so by using:
• Margin-The account custodian or broker-dealer lends money to the client. The
custodian charges the client interest for the right to borrow money, and uses the
assets in the client’s brokerage account as collateral or
• Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a
loan to the client, the client pledges its investment assets held at the account
custodian as collateral;
These above-described collateralized loans are generally utilized because they typically
provide more favorable interest rates than standard commercial loans. These types of
collateralized loans can assist with a pending home purchase, permit the retirement of more
expensive debt, or enable borrowing in lieu of liquidating existing account positions and
incurring capital gains taxes. However, such loans are not without potential material risk to
the client’s investment assets. The lender (i.e., custodian, bank, etc.) will have recourse
against the client’s investment assets in the event of loan default or if the assets fall below
a certain level. For this reason, Registrant does not recommend such borrowing unless it is
for specific short-term purposes (i.e., a bridge loan to purchase a new residence). Registrant
does not recommend such borrowing for investment purposes (i.e., to invest borrowed funds
in the market). Regardless, if the client was to determine to utilize margin or a pledged assets
loan, the following economic benefits would inure to Registrant:
• by taking the loan rather than liquidating assets in the client’s account, Registrant
continues to earn a fee on such Account assets; and,
• if the client invests any portion of the loan proceeds in an account to be managed
by Registrant, Registrant will receive an advisory fee on the invested amount; and,
• if Registrant’s advisory fee is based upon the higher margined account value (see
margin disclosure at Item 5 below), Registrant will earn a correspondingly higher
advisory fee. This could provide Registrant with a disincentive to encourage the
client to discontinue the use of margin.
Please Note: The Client must accept the above risks and potential corresponding
consequences associated with the use of margin or a pledged assets loans.
Cybersecurity Risk. The information technology systems and networks that Registrant
and its third-party service providers use to provide services to Registrant’s clients employ
various controls, which are designed to prevent cybersecurity incidents stemming from
intentional or unintentional actions that could cause significant interruptions in Registrant’s
operations and result in the unauthorized acquisition or use of clients’ confidential or non-
public personal information. Clients and Registrant are nonetheless subject to the risk of
cybersecurity incidents that could ultimately cause them to incur losses, including for
example: financial losses, cost and reputational damage to respond to regulatory
obligations, other costs associated with corrective measures, and loss from damage or
interruption to systems. Although Registrant has established processes to reduce the risk
of cybersecurity incidents, there is no guarantee that these efforts will always be successful,
especially considering that Registrant does not directly control the cybersecurity measures
and policies employed by third-party service providers. Clients could incur similar adverse
consequences resulting from cybersecurity incidents that more directly affect issuers of
securities in which those clients invest, broker-dealers, qualified custodians, governmental
and other regulatory authorities, exchange and other financial market operators, or other
financial institutions.
Unaffiliated Private Investment Funds. Registrant provides investment advice regarding
unaffiliated private investment funds, which may include recommendations that certain
qualified clients consider investing in one or more private investment funds. Registrant’s
role in this respect will be limited to initial and ongoing due diligence and investment
monitoring services. If a client determines to become an unaffiliated private fund investor,
the amount of assets invested in the respective fund(s) will be included as part of “assets
under management” for purposes of Registrant calculating its investment advisory fee
(unless Registrant expressly agrees otherwise, in writing). Registrant’s clients are under
absolutely no obligation to consider or make an investment in a private investment fund(s).
Private investment funds involve various risk factors as further described in Item 8 below.
Unlike liquid investments that a client may own, private investment funds do not provide
daily liquidity or pricing. Each prospective client investor will be required to complete a
Subscription Agreement, pursuant to which the client shall establish qualification for
investment in the fund and acknowledges and accepts the various risk factors that are
associated with such an investment.
Unaffiliated Private Investment Fund Valuation.
In the event that Registrant references private investment funds owned by the client on any
supplemental account reports prepared by Registrant, the value(s) for all private investment
funds owned by the client shall reflect the most recent valuation provided by the fund
sponsor. However, if subsequent to purchase, the fund has not provided an updated
valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase,
the fund provides an updated valuation, then the statement will reflect that updated value.
The updated value will continue to be reflected on the report until the fund provides a
further updated value. Please Also Note: As result of the valuation process, if the valuation
reflects initial purchase price or an updated value subsequent to purchase price, the current
value(s) of an investor’s fund holding(s) could be significantly more or less than the value
reflected on the report. Unless otherwise indicated, Registrant shall calculate its fee based
upon the latest value provided by the fund sponsor.
Custodian Charges – Additional Fees. As discussed in Item 12 below, unless the client
directs otherwise or an individual client’s circumstances require, the Registrant will
generally recommend that Charles Schwab and Co., Inc., and its affiliates (“Schwab”) to
serve as the broker-dealer/custodian for client investment advisory assets. In limited
circumstances, the Registrant may recommend Rockbridge Capital or Chicago Pacific
Founders.
Broker-dealers such as Schwab charge brokerage commissions, transaction, and/or other
type fees for effecting certain types of securities transactions (i.e., including transaction
fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income
transactions, etc.). The types of securities for which transaction fees, commissions, and/or
other type fees (as well as the amount of those fees) shall differ depending upon the broker-
dealer/custodian. While certain custodians, including Schwab, generally (with the potential
exception for large orders) do not currently charge fees on individual equity transactions
(including ETFs), others do. There can be no assurance that Schwab will not change their
transaction fee pricing in the future. Schwab may also assess fees to clients who elect to
receive trade confirmations and account statements by regular mail rather than
electronically.
Use of Mutual Funds and Exchange Traded Funds. Registrant utilizes mutual funds and
exchange traded funds for its client portfolios. In addition to Registrant’s investment
advisory fee described below, and transaction and/or custodial fees discussed below, clients
will also incur, relative to all mutual fund and exchange traded fund purchases, charges
imposed at the fund level (e.g., management fees and other fund expenses). The mutual
funds and exchange traded funds utilized by the Registrant are generally available directly
to the public. Thus, a client can generally obtain the funds recommended and/or utilized by
Registrant independent of engaging Registrant as an investment advisor. However, if a
prospective client does so, then they will not receive Registrant's initial and ongoing
investment advisory services.
Please Note - Use of DFA Mutual Funds. Registrant utilizes the mutual funds
issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally only
available through registered investment advisers approved by DFA. Thus, if the
client was to terminate Registrant’s services, and transition to another adviser who
has not been approved by DFA to utilize DFA funds, restrictions regarding
additional purchases of, or reallocation among other DFA funds, will generally
apply. ANY QUESTIONS: Registrant’s Chief Compliance Officer, Geoffrey
Biehn, remains available to address any questions that a client or prospective
client may have regarding the above.
Investment Risk. Different types of investments involve varying degrees of risk, and it
should not be assumed that future performance of any specific investment or investment
strategy (including the investments and/or investment strategies recommended or
undertaken by Registrant) will be profitable or equal any specific performance level(s).
Disclosure Brochure. A copy of the Registrant’s written Brochure as set forth on Part 2A
of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each
client prior to, or contemporaneously with, the execution of an agreement between the
client and the Registrant.
C. The Registrant provides investment advisory services tailored specifically to the needs of
each client. Before providing investment advisory services, an investment adviser
representative will ascertain each client’s investment objective(s). Thereafter, the
Registrant shall allocate and/or recommend that the client allocate investment assets
consistent with the designated investment objective(s). The client may, at any time, impose
reasonable restrictions, in writing, on the Registrant’s services.
D. The Registrant does not participate in a wrap fee program.
E. As of December 31, 2023, the Registrant had $486,380,919 in assets under management
on a discretionary basis and $1,417,021 in assets under management on a non-discretionary
basis, for a total of $487,797,940 in assets under management.