Description of Services
The TSFG, LLC Wrap Program (the Program) is an investment advisory program sponsored by
TSFG, LLC (TSFG). The Program provides clients with the ability to trade in certain investment
products without incurring separate brokerage commissions or transaction charges.
To join the Program a person must:
1) Provide information about their financial needs, investment objectives, time horizon, and
risk tolerance, as well as any other factors relevant to their specific financial situation and
any other supporting documentation required for the Program;
2) Complete a new account agreement with the broker dealer approved by TSFG for
participation in the Program (Broker-Dealer); and
3) Open a securities brokerage account with the Broker-Dealer (an Account) and deposit
those client assets designated for participation in the Program (Program Assets) into the
Account.
After an analysis of any information provided by the client to TSFG, we shall assist the client in
developing an appropriate investment strategy for the Program Assets in their Account(s) (the
Investment Strategy). Thereafter, all clients are encouraged to discuss their needs, goals, and
objectives with TSFG and to keep TSFG informed of any changes thereto. TSFG shall contact
clients at least annually to review its previous services and/or recommendations and to determine
whether changes should be made to their Investment Strategy.
Management of Your Portfolio
All clients in the Program shall grant TSFG discretionary authority to buy, sell, and otherwise trade
in the type of securities described in Item 6 (below) for their Account(s) and to liquidate previously-
purchased securities that the client has transferred to their Account(s). Program Assets in the
client’s Account(s) shall be managed by one of TSFG’s investment adviser representatives.
The Program may recommend that clients authorize the active discretionary management of
certain Program Assets by and/or among one or more independent investment managers
(Independent Managers) to implement a particular Investment Strategy. The terms and
conditions under which the client shall engage the Independent Manager(s) may be set forth in
separate written agreements between (1) the client and TSFG and (2) TSFG or client and the
designated Independent Manager(s). TSFG shall continue to render advisory services to the client
relative to the ongoing monitoring and review of account performance, for which TSFG shall
receive an annual advisory fee which is based upon a percentage of the market value of the
Program Assets being managed by the designated Independent Manager(s). Factors that the
Registrant shall consider in recommending Independent Manager(s) include the client’s stated
investment objective(s), management style, performance, reputation, financial strength, reporting,
pricing, and research. In addition to TSFG’s written disclosure statement, the client shall also
receive the written disclosure statement of the designated Independent Manager(s).
Neither TSFG nor the client may assign the Program Agreement without the consent of the other
party. Transactions that do not result in a change of actual control or management of TSFG shall
not be considered an assignment.
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Fees for Participation in the Program
Clients in the Program pay a single annualized fee for participation in the Program (the Program
Fee). TSFG shall charge an annual fee based upon a percentage of the market value of the assets
being managed by TSFG. TSFG’s annual fee shall be prorated and charged quarterly, in
advance, based upon the market value of the assets being managed by TSFG on the last day of
the previous quarter. For the initial fee, it will be deducted at the beginning of the quarter following
the establishment of the account and will include a prorated fee for the initial quarter in addition
to the quarterly fee for the upcoming
quarter. Subsequent fee deductions will be made at the
beginning of each quarter based on the value of the Account assets as of the close of business
on the last business day of the preceding quarter. Additional deposits and withdrawals will be
added or subtracted from the assets, which may lead to an adjustment of TSFG’s fee. If the
custodian is notified by Client or TSFG of the termination or deactivation of the Account’s advisory
account status at the custodian, the custodian will process a prorated refund of Advisor’s fees
that were pre-paid based upon the number of days remaining in the quarter after the notice of
termination to the custodian and TSFG. Certain accounts may establish procedures to pay the
Advisor’s fee directly rather than through a debit to the Account. Any different method of billing
fees may result in the imposition of additional charges to cover the administrative costs of billing.
The annual fee shall vary (up to 2.00% and are negotiable) depending upon the market value of
the assets under management.
TSFG, in its sole discretion, may negotiate to charge a lesser management fee based upon certain
criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount
of assets to be managed, related accounts, account composition, pre-existing client, account
retention, pro bono activities, etc.).
Under the Program, clients receive both investment advisory services and the execution of
transactions in securities for a single, combined annualized fee, the Program Fee. Participation
in the Program may cost the client more or less than purchasing such services separately. The
number of transactions made in the client’s Account(s), as well as the commissions charged for
each transaction, will determine the relative cost of the Program versus paying for execution on
a per transaction basis and paying a separate fee for advisory services. The Program Fee may
be higher or lower than fees charged by other sponsors of comparable investment advisory
programs.
Clients may incur certain charges imposed by third parties in addition to the Program Fee such
as fees charged by Independent Managers, charges imposed directly by a mutual fund or
exchange traded fund in the account, which shall be disclosed in the fund’s prospectus (e.g., fund
management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer
taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts
and securities transactions.
Fees for Management During Partial Quarters of Service
For the initial period of participation in the Program, the Program Fee shall be calculated on a pro
rata basis. The Program Agreement between TSFG and the client will continue in effect until
terminated by either party pursuant to the terms of the Program Agreement. The Program Fee
shall be prorated through the date of termination and any remaining balance shall be refunded to
the client in a timely manner.
Additions may be in cash or securities provided that TSFG reserves the right to liquidate any
transferred securities, or decline to accept particular securities into a client’s account. TSFG may
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consult with its clients about the options and ramifications of transferring securities. However,
clients are advised that when transferred securities are liquidated, they are subject to transaction
fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax
ramifications.
If assets are deposited into or withdrawn from an account after the inception of a quarter, the
Program Fee with respect to such assets will be prorated based on the number of days remaining
in the quarter.
Assets Under Management
As of December 2022, TSFG manages approximately $577,279,547 in assets under
management; all assets are managed on a discretionary basis.
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