WRAP BROCHURE
Trufp (CRD 299212), brochure dated March 3, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure
Form ADV, Part 2A, Item 1
Cover Page
Investment Planning Advisors
d/b/a
TruFP
3550 Rowe Lane
Cumming, GA 30041
Tel: (770) 205-4394
3/3/2026
FORM ADV PART 2A APPENDIX 1
WRAP FEE PROGRAM BROCHURE
This brochure provides information about the qualifications and business practices of
Investment Planning Advisors. If you have any questions about the contents of this brochure,
please contact us at (770) 205-4394. The information in this brochure has not been approved or
verified by the United States Securities and Exchange Commission or by any state securities
authority.
Additional information about Investment Planning Advisors is also available on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Investment
Planning Advisors is 299212.
Investment Planning Advisors is a Registered Investment Adviser. Registration with the United
States Securities and Exchange Commission or any state securities authority does not imply a
certain level of skill or training.
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Form ADV, Part 2A Appendix 1, Item 2
Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure. Each year, we will ensure that
you receive a summary of any material changes to this and subsequent brochures by April 30th.
We will further provide you with our most recent brochure at any time at your request, without
charge. You may request a brochure by contacting us at (770) 205-4394.
Material Changes since the Last Update
Investment Planning Advisors was established as a new Registered Investment Advisor in
January 2019 under the State of Georgia rules and regulations. Investment Planning Associates
was established as a Registered Investment Advisor in October 2019 with the Securities and
Exchange Commission (“SEC”), under the rules and regulations of the US Investment Advisers
Act of 1940, as amended (the "Advisers Act").
The following Material Changes were made since the last update on January 8, 2026:
• The Firm moved its primary location from 327 Dahlonega Street, Suite 503, Cumming,
GA 30040 to their new location at 3550 Rowe Lane, Cumming, GA 30041.
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Form ADV, Part 2A Appendix 1, Item 3
Table of Contents
Services, Fees and Compensation……………………………………….…4
Account Requirements and Types of Clients……………………………..7
Portfolio Manager Selection and Evaluation………………………………7
Client Information Provided to Portfolio Managers…………...…….….10
Client Contact with Portfolio Managers…………………………………..11
Additional Information....…………………………………………………….11
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Form ADV Part 2A Appendix 1, Item 4
Services, Fees and Compensation
Investment Planning Advisors d/b/a TruFP (hereinafter called “TruFP”) is a Registered
Investment Adviser based in Cumming, Georgia, and incorporated under the laws of the State
of Georgia. TruFP is owned by Kenneth Bellavance and Andrew Castleberry. TruFP is
registered with the U.S. Securities and Exchange Commission and is subject to its rules and
regulations. Investment Planning Advisors was founded in January 2019 as a State of Georgia
independently registered investment advisor and registered in October 2019 with the U.S.
Securities and Exchange Commission (“SEC”). TruFP provides investment advisory services,
which may include, but are not limited to, the review of client investment objectives and goals,
recommending asset allocation strategies of managed assets among investment products such
as cash, stocks, mutual funds and bonds, annuities, and/or preparing written investment
strategies. Our investment advice is tailored to meet our clients’ needs and investment
objectives. Clients may impose restrictions on investing in certain securities or types of
securities (such as a product type, specific companies, specific sectors, etc.) by providing a
signed and dated written notification, of which an e-mail is also an acceptable form of
notification. TruFP also provides financial planning consulting services including, but not
limited to, risk assessment/management, investment planning, estate planning, financial
organization, or financial decision making/negotiation.
TruFP provides investment advisory and other financial services through its Investment
Advisory Representatives ("IAR") to accounts opened with TruFP. Managed Accounts are
available to individuals and high net worth individuals.
TruFP provides discretionary and non-discretionary investment advisory services to some of
its clients through various managed account programs. TruFP will assist clients in
determining the suitability of the managed account programs for the client. The IAR is
compensated through a comprehensive single fee and the account may be assessed other
charges associated with conducting a brokerage business. TruFP and its IAR, as appropriate,
will be responsible for the following:
• Performing due diligence
• Recommending strategic asset and style allocations
• Providing research on investment product options, as needed
• Providing client risk profile questionnaire
• Obtaining investment advisory contract from client with required financial, risk tolerance,
suitability and investment vehicle selection information for each new account
• Performing client suitability check on account documentation, review the investment
objectives and evaluate the investment vehicle selections
• Providing Firm Brochure (this document)
TruFP may recommend a Wrap Fee Program for the client’s account(s). A “Wrap Fee
Program” for purposes of the SEC is a program under which investment advisory and
brokerage execution services are provided for a single “wrapped” fee that is not based on the
transactions in a client account. TruFP provides discretionary and non-discretionary
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investment advisory services to some of its clients through a Wrap Fee Program. TruFP will
assist clients in determining the suitability of the Wrap Fee Program for the client. Wrap Fee
Program accounts recommended by TruFP are not managed differently from non-Wrap Fee
Program accounts. Because brokerage execution costs are included in the client’s overall
advisory fee, the client’s fee may be greater than those that have accounts in non-Wrap Fee
Program accounts, however fees will not exceed the fee schedule stated in this Wrap Fee
Brochure. All clients with Wrap Fee Program accounts will be provided with this Wrap Fee
Brochure.
TruFP offers a clearing platform to execute securities business for investment advisory
services, including Wrap Fee Program services, through Charles Schwab (“Schwab”). In
order for TruFP to provide asset management services, we request you utilize the brokerage
and custodial services of Schwab. Schwab is an independent SEC-registered broker dealer and
is separate and unaffiliated with TruFP. Schwab offers services to independently registered
investment advisors which include custody of securities, trade execution and clearance and
settlement of transactions.
TruFP’s relationship with Schwab may include benefits provided to our firm, including, but
not limited to research, market information, and administrative services that help our firm
manage your account(s). These services may be provided for free or at a discount by Schwab
or third-party vendors. The benefits provided to TruFP do not depend on the amount of
brokerage transactions directed to Schwab. We believe that recommended broker-dealers
provide quality execution services for our clients at competitive prices. Price is not the sole
factor we consider in evaluating best execution. We also consider the quality of the brokerage
services provided by the recommended broker-dealers, including the value of research
provided, the firm’s reputation, execution capabilities, commission rates, and responsiveness
to our clients and our firm.
Fees and Compensation
The following types of fees will be assessed:
Asset Management – Fees are charged monthly or quarterly in advance and are based primarily
on asset size and the level of complexity of the services provided. In individual cases, TruFP has
the sole discretion to negotiate fees that are lower than the standard fee shown or to waive fees.
Fees are not based on the share of capital gains or capital appreciation of the funds or any portion
of the funds. Comparable services for lower fees may be available from other sources. Fees for
the initial month (or quarter) will be prorated based upon the number of calendar days in the
calendar month (or quarter) that the advisory agreement is in effect. Fees are based on the
market value of the assets on the last business day of the previous month (or quarter). Annual
fees range from .30% - 1.00% depending on the amount of assets under management (“AUM”) –
See chart below. Consulting services are included in these fees for asset management services
with the exception of unique circumstances that may require a separate agreement for financial
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planning services (description and fees are discussed below). If the situation warrants separate
financial planning fees, it will be discussed upfront and a separate agreement will be negotiated.
Fee Schedule for Asset Management:
Maximum Annual Advisory Fee
Total Account Value
$0 - $250,000 1.00%
Next $250,001 - $1,000,000 0.80%
Next $1,000,001 - $2,500,000 0.60%
Next $2,500,001 - $5,000,000 0.50%
Next $5,000,001 - $10,000,000 0.40%
Next $10,000,001 – and above 0.30%
As authorized in the client agreement, the account custodian withdraws Investment Planning
Advisors’ advisory fees directly from the clients’ accounts according to the custodian’s policies,
practices, and procedures. The custodial statement includes the amount of any fees paid to
TruFP for advisory services. You should carefully review the statement from your
custodian/broker-dealer’s statement and verify the calculation of fees. Your custodian/broker-
dealer does not verify the accuracy of fee calculations.
Fees are charged in advance on a monthly or quarterly basis, meaning that advisory fees for a
month are charged on the first day of the month (or quarter). Clients may terminate investment
advisory services obtained from TruFP, without penalty, upon written notice within five (5)
business days after entering into the advisory agreement with TruFP. Thereafter, the client may
terminate advisory services upon written notice delivered to and received by TruFP. Clients who
terminate investment advisory services during a month are charged a prorated advisory fee based
on the date of TruFP’s receipt of client’s written notice to terminate. Any earned but unpaid fees
are immediately due and payable, and any pre-paid and unearned fee will be immediately
refunded.
Financial Planning – Financial planning services are charged in advance through a fixed fee or
hourly arrangement as agreed upon between the client and Investment Planning Advisors. There
will never be an instance where $1200 or more in fees is charged six or more months in advance.
Hourly fees are generally charged when the scope of services cannot be determined or if the
services are limited to one meeting. Fixed fees are generally quoted to the client for longer term
consulting projects. Fees are negotiable and vary depending upon the complexity of the client
situation and services to be provided. Hourly fees range from $175 - $250 per hour, depending
on what is negotiated between TruFP and the client. Similar financial planning services may be
available elsewhere for a lower cost to the client. Fixed fees range from $1,000 - $20,000
depending on what is negotiated between the client and TruFP, and the complexity of the project.
An estimate for total hours and charges is determined at the start of the advisory relationship.
Typically, clients will be invoiced monthly for all time spent by TruFP as agreed upon by client
or upon completion of the services if less than a month. Clients who wish to terminate the
planning process prior to completion may do so with written notice. The client may obtain a
refund of a pre-paid fee if the advisory contract is terminated before the end of the billing period
by contacting Kenneth Bellavance at (770) 205-4394. Upon receipt of written notification, any
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earned fee will immediately become due and payable, and any pre-paid and unearned fee will be
immediately refunded. A client may terminate an advisory agreement without being assessed
any fees or expenses within five (5) days of its signing.
Additional Fees and Expenses
Fees and charges incurred by the client from third parties as a result of maintaining the account
such as transaction fees for any securities transactions executed and account maintenance or
custodial fees are included in the wrap fees as stated in the above fee schedule. These fees vary
by broker and/or custodian. For any mutual funds purchased, the client may pay their
proportionate share of the funds’ distribution, internal management, investment advisory and
administrative fees. Such fees are not shared with TruFP and are compensation to the fund
manager. Clients are urged to read the mutual fund prospectus prior to investing.
Mutual fund companies impose internal fees and expenses on clients. These fees are in addition
to the costs associated with the investment advisory services as described above. Complete
details of such internal expenses are specified and disclosed in each mutual fund company’s
prospectus. Clients are strongly advised to review the prospectus(es) prior to investing in such
securities.
Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that
would not exist if the purchase or sale were made directly with the mutual fund company.
Mutual funds held in broker-dealer accounts also charge management fees. These mutual fund
management fees may be more or less than the mutual fund management fees charged if the
client held the mutual fund directly with the mutual fund company.
Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal
underwriter, or a distributor without purchasing the services of TruFP or paying the advisory fee
on such shares (but subject to any applicable sales charges). Certain mutual funds are offered to
the public without a sales charge. In the case of mutual funds offered with a sales charge, the
prevailing sales charge (as described in the mutual fund prospectus) may be more or less than the
applicable advisory fee. However, clients would not receive TruFP’s assistance in developing an
investment strategy, selecting securities, monitoring performance of the account, and making
changes as necessary.
Please refer to Item 12 “Brokerage Practices” of this brochure for additional information.
Form ADV, Part 2A Appendix 1, Item 5
Account Requirements and Types of Clients
TruFP offers investment advisory services primarily to individuals and high net worth
individuals. There is generally a $25,000 minimum account size to open and maintain an
advisory account, however TruFP may waive the minimum at its discretion.
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Form ADV, Part 2A Appendix 1, Item 6
Portfolio Manager Selection and Evaluation
TruFP may act as the portfolio manager for its Wrap Fee Program accounts. There is no conflict
of interest with the arrangement.
Advisory Business
Investment Planning Advisors d/b/a TruFP (hereinafter called “TruFP”) is a Registered
Investment Adviser based in Cumming, Georgia, and incorporated under the laws of the State of
Georgia. TruFP is owned by Kenneth Bellavance and Andrew Castleberry. TruFP is registered
with the U.S. Securities and Exchange Commission and is subject to its rules and regulations.
Investment Planning Advisors was founded in January 2019 as a State of Georgia independently
registered investment advisor and registered in October 2019 with the U.S. Securities and
Exchange Commission (“SEC”). TruFP provides investment advisory services, which may
include, but are not limited to, the review of client investment objectives and goals,
recommending asset allocation strategies of managed assets among investment products such as
cash, stocks, mutual funds and bonds, annuities, and/or preparing written investment strategies.
Our investment advice is tailored to meet our clients’ needs and investment objectives. Clients
may impose restrictions on investing in certain securities or types of securities (such as a product
type, specific companies, specific sectors, etc.) by providing a signed and dated written
notification, of which an e-mail is also an acceptable form of notification. TruFP also provides
financial planning consulting services including, but not limited to, risk assessment/management,
investment planning, estate planning, financial organization, or financial decision
making/negotiation.
TruFP provides investment advisory and other financial services through its Investment
Advisory Representatives ("IAR") to accounts opened with TruFP. Managed Accounts are
available to individuals and high net worth individuals.
Asset Management
Investment Planning Advisors provides discretionary and non-discretionary investment advisory
services to some of its clients through various managed account programs. Investment Planning
Advisors will assist clients in determining the suitability of the Managed Account Programs for
the client. The IAR is compensated through a comprehensive single fee and the account may be
assessed other charges associated with conducting a brokerage business. The firm and its IAR, as
appropriate, will be responsible for the following:
• Performing due diligence
• Recommending strategic asset and style allocations
• Providing research on investment product options, as needed
• Providing client risk profile questionnaire
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• Obtaining investment advisory contract from client with required financial, risk tolerance,
suitability and investment vehicle selection information for each new account
• Performing client suitability check on account documentation, reviewing the investment
objectives and evaluating the investment vehicle selections
• Providing Firm Brochure (this document)
TruFP may recommend a Wrap Fee Program for the client’s account(s). A “Wrap Fee Program”
for purposes of the SEC is a program under which investment advisory and brokerage execution
services are provided for a single “wrapped” fee that is not based on the transactions in a client
account. TruFP provides discretionary investment advisory services to some of its clients
through a Wrap Fee Program. TruFP will assist clients in determining the suitability of the Wrap
Fee Program for the client. Wrap Fee Program accounts recommended by TruFP are not
managed differently from non-Wrap Fee Program accounts. Because brokerage execution costs
are included in the client’s overall advisory fee, the client’s fee may be greater than those that
have accounts in non-Wrap Fee Program accounts, however fees will not exceed the fee schedule
stated in this Wrap Fee Brochure. All clients with Wrap Fee Program accounts will be provided
with this Wrap Fee Brochure. This Brochure is focused on Wrap Fee Program accounts.
As of January 5, 2026, the firm has the following assets under management:
Discretionary:
Non-Discretionary:
Total:
$421,795,0801
$0
$421,795,0801
Performance-Based Fees and Side by Side Management
TruFP does not charge performance-based fees or participate in side-by-side management. Side-
by-side management refers to the practice of managing accounts that are charged performance-
based fees while at the same time managing accounts that are not charged performance-based
fees. Performance-based fees are fees that are based on a share of capital gains or appreciation
of the assets of a client. Our fees are calculated as described in Fees and Compensation section
above and are not charged on the basis of performance of your advisory account.
Methods of Analysis, Investment Strategies, and Risk of Loss
TruFP’s methods of analysis and investment strategies incorporate the client’s needs and
investment objectives, time horizon, and risk tolerance. TruFP is not bound to a specific
investment strategy for the management of investment portfolios, but rather consider the risk
tolerance range of each portfolio and the risk level of each level when the account is opened.
Examples of methodologies that our investment strategies may incorporate include:
Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix
of asset classes and the efficient allocation of capital to those assets by matching rates of return
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to a specified and quantifiable tolerance for risk. Asset Allocation has the potential of all the
risks listed below.
Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount
of securities at regularly scheduled intervals, regardless of the price per share. This will
gradually, over time, decrease the average share price of the security. Dollar-cost averaging
lessens the risk of investing a large amount in a single investment at the wrong time. Dollar-Cost
Averaging has the potential of all the risks listed below.
Technical Analysis – involves studying past price charts, patterns and trends in the financial
markets to predict the direction of both the overall market and specific stocks. Technical
Analysis has the potential of all the risks listed below.
Long-Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year. Long-
Term Purchases have the potential of all the risks listed below.
Short-Term Purchases – securities purchased with the expectation that they will be sold within
a relatively short period of time, generally less than one year, to take advantage of the securities’
short-term price fluctuations. Short-term Purchases primarily have the potential of Market Risk,
Business Risk, and Liquidity Risk as listed below.
Our strategies and investments may have unique and significant tax implications. Regardless of
your account size or other factors, we strongly recommend that you continuously consult with a
tax professional prior to and throughout the investing of your assets.
Investing in securities involves risk of loss that clients should be prepared to bear. Although we
manage your portfolio with strategies and in a manner consistent with your risk tolerances, there
can be no guarantee that our efforts will be successful. You should be prepared to bear the risk
of loss.
All investments involve the risk of loss, including (among other things) loss of principal, a
reduction in earnings (including interest, dividends, and other distributions), and the loss of
future earnings. Regardless of the methods of analysis or strategies suggested for your particular
investment goals, you should carefully consider these risks, as they all bear risks.
TruFP’s primary goal for investing is to help the client maintain purchasing power over the long
term. This may result in short term variability and loss of principal. Time horizon and risk
tolerance are key determinates of the proper asset allocation. TruFP’s approach focuses on
taking appropriate risks for which clients are compensated (i.e. market risk) and seeking to limit
or eliminate risks that do not provide compensation over the long term (i.e. individual stock risk
or lack of portfolio risk).
Below are some more specific risks of investing:
Market Risk. The prices of securities in which clients invest may decline in response to certain
events taking place around the world, including those directly involving the companies whose
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securities are owned by the client or an underlying fund; conditions affecting the general
economy; overall market changes; local, regional or global political, social or economic
instability; and currency, interest rate and commodity price fluctuations. Investors should have a
long-term perspective and be able to tolerate potentially sharp declines in market value.
Management Risk. TruFP’s investment approach may fail to produce the intended results. If
our perception of the performance of a specific asset class or underlying fund is not realized in
the expected time frame, the overall performance of client’s portfolio may suffer.
Equity Risk. Equity securities tend to be more volatile than other investment choices. The value
of an individual mutual fund or ETF can be more volatile than the market as a whole. This
volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are
subject to additional risks. Smaller companies may experience greater volatility, higher failure
rates, more limited markets, product lines, financial resources, and less management experience
than larger companies. Smaller companies may also have a lower trading volume, which may
disproportionately affect their market price, tending to make them fall more in response to
selling pressure than is the case with larger companies.
Fixed Income Risk. The issuer of a fixed income security may not be able to make interest and
principal payments when due. Generally, the lower the credit rating of a security, the greater the
risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower
rating, the value of the debt security will decline because investors will demand a higher rate of
return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. A
nominal interest rate is the sum of a real interest rate and an expected inflation rate.
Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and may
be affected by adverse political, legislative and tax changes, as well as by financial developments
that affect the municipal issuers. Because many municipal obligations are issued to finance
similar projects by municipalities (e.g., housing, healthcare, water and sewer projects, etc.),
conditions in the sector related to the project can affect the overall municipal market. Payment
of municipal obligations may depend on an issuer’s general unrestricted revenues, revenue
generated by a specific project, the operator of the project, or government appropriation or aid.
There is a greater risk if investors can look only to the revenue generated by the project. In
addition, municipal bonds generally are traded in the “over-the-counter” market among dealers
and other large institutional investors. From time to time, liquidity in the municipal bond market
(the ability to buy and sell bonds readily) may be reduced in response to overall economic
conditions and credit tightening.
Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the
client indirectly bears its proportionate share of any fees and expenses payable directly by those
funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In
addition, the client’s overall portfolio may be affected by losses of an underlying fund and the
level of risk arising from the investment practices of an underlying fund (such as the use of
derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a
market price that is above or below their net asset value; (ii) the ETF may employ an investment
strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the
listing exchange’s officials deem such action appropriate, the shares are de-listed from the
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exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases
in stock prices) halts stock trading generally. TruFP has no control over the risks taken by the
underlying funds.
Artificial Intelligence and Machine Learning Risk. Certain service providers utilized by the
Firm to service client accounts have artificial intelligence components. The use of artificial
intelligence and machine learning includes increased risk of data inaccuracies and security
vulnerabilities. Due to the rapid advancement of machine learning technologies, future risks
related to artificial intelligence are unpredictable. As a measure to mitigate these risks to our
clients, the Firm performs periodic due diligence of our service providers for assurance that the
service providers have appropriate controls in place to protect our clients’ information and to
limit data inaccuracies when artificial intelligence is used by the service provider.
Voting Client Securities
TruFP does not vote proxies on behalf of Client advisory accounts. At the Client’s request,
TruFP may offer the Client advice regarding corporate actions and the exercise of proxy voting
rights. If the Client owns shares of common stock or mutual funds, the Client is responsible for
exercising the right to vote as a shareholder.
In most cases, the Client will receive proxy materials directly from the account custodian.
However, in the event TruFP receives any written or electronic proxy materials, we would
forward them directly to the Client by mail, unless the Client has authorized our firm to contact
you by electronic mail, in which case, TruFP would forward any electronic solicitation to vote
proxies.
Form ADV, Part 2A Appendix 1, Item 7
Client Information Provided to Portfolio Managers
TruFP may directly provide the portfolio management services for the Wrap Fee Program
accounts. As such, TruFP receives all information provided by the Client through a formal
Needs Analysis and consultation with the Client. Advice is provided through consultation with
the client and may include: determination of financial objectives, identification of financial
problems, cash flow management, tax planning, insurance review, investment management,
education funding, retirement planning, and estate planning.
Form ADV, Part 2A Appendix 1, Item 8
Client Contact with Portfolio Managers
There are no restrictions placed on TruFP’s clients’ ability to contact and consult with their
portfolio manager(s).
Form ADV, Part 2A Appendix 1, Item 9
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Additional Information
Disciplinary Information
TruFP or its Principal Executive Officers have not had any reportable disclosable events in the
past ten years.
Other Financial Industry Activities and Affiliations
The IARs of TruFP are not currently registered with any broker dealer.
Neither TruFP nor its representatives are registered as a Futures Commission Merchant,
Commodity Pool Operator, or a Commodity Trading Advisor.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
TruFP’s Code of Ethics includes guidelines for professional standards of conduct for our
Associated Persons. Our goal is to protect client interests at all times and to demonstrate our
commitment to fiduciary duties of honesty, good faith, and fair dealing. All of TruFP’s
Associated Persons are expected to strictly adhere to these guidelines. Persons associated with
TruFP are also required to report any violations to the Code of Ethics. Additionally, the firm
maintains and enforces written policies reasonably designed to prevent the misuse or
dissemination of material, non-public information about our clients or client accounts by persons
associated with our firm.
TruFP may buy or sell securities for itself that we also recommend to clients. In addition, the
individual IARs may buy or sell the same securities for their personal and family accounts that
are bought and sold for your account(s).
TruFP or its IARs may have an interest or position in a certain security, which may also be
recommended to the client. As these situations may present a conflict of interest, TruFP has
established the following restrictions in order to ensure its fiduciary responsibilities:
A director, officer or employee of the advisor shall not buy or sell a security for their
The advisor requires that all employees must act in accordance with all applicable
The advisor will monitor any blocking of personal trades with those of clients to ensure
1.
personal portfolio(s) where their decision is substantially derived, in whole or part, by reason of
his or her employment, unless the information is also available to the investing public. No
owner/employee of TruFP shall prefer their own interest to that of the client.
The advisor maintains a list of all securities held by the company and all directors,
2.
officers, and employees. These holdings are reviewed on a quarterly basis by the principal of the
firm.
3.
Federal and State regulations governing registered investment advisors.
4.
that clients are not at a disadvantage.
TruFP’s Code of Ethics is available to you upon request. You may obtain a copy of our Code of
Ethics by contacting Kenneth Bellavance at (770) 205-4394.
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Review of Accounts
Client accounts are reviewed at least quarterly by Kenneth Bellavance, the Principal Executive
Officer of the firm. Client accounts are reviewed with regard to their investment policies and risk
tolerance levels. All accounts at TruFP are reviewed by this reviewer.
Reviews may also be triggered by material market, economic or political events, or by changes
in client's financial situations (such as retirement, termination of employment, physical move, or
inheritance).
Each client will receive at least quarterly a written report that details the clients’ account which
may come from the custodian.
Client Referrals and Other Compensation
TruFP advertises their investment advisory services on the website of The Lampo Group, LLC
d/b/a Ramsey Solutions™ (“RS”), which operates a program known as SmartVestor™. As the
Securities and Exchange Commission deems RS to be a third-party solicitor within the meaning
of Rule 206(4)-3 under the Investment Advisers Act of 1940, TruFP makes the following
disclosure: SmartVestor™ is an advertising service for investing professionals. When a
consumer provides contact information through the SmartVestor™ website, the program
introduces the consumer to up to five (5) investing professionals (“Pros”) in their geographic
area. It is up to the consumer to interview the Pros and decide whether to directly retain them. As
a SmartVestor™ Pro, TruFP pays RS a flat monthly membership and advertising fee to advertise
their services in the SmartVestor™ Program. In return, TruFP receives contact information for
prospective investment advisory clients. Consumers entering a zip code corresponding to
TruFP’s advertising markets can view their profile, and other Pros in the same markets, on the
SmartVestor™ website. The advertising fee is based upon criteria including market size (small,
medium, large or premium) and historic volume of web traffic to RS’s SmartVestor™ website.
The fees paid by TruFP are irrespective of whether someone becomes a client, and the fees are
not passed on to the client. The fees paid are not based upon the number of leads, contacts, or
referrals which TruFP may receive from RS or the SmartVestor™ website. TruFP do not pay to
or share with RS or SmartVestor™ any portion of the investment advisory fees a client is
charged. Neither RS nor its affiliates are engaged in providing investment advice. RS does not
receive, control, access or monitor client funds, accounts, or portfolios of TruFP. Any services
rendered by TruFP are solely their services and not those of RS or SmartVestor™.
TruFP does not receive compensation for referrals made to other professional service providers.
Financial Information
TruFP is not required to provide financial information to our clients because we do not require or
solicit the prepayment of more than $1200 six or more months in advance.
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Form ADV, Part 2A Appendix 1, Item 10
Requirements for State-Registered Advisers
This section is not applicable because the firm is registered with the SEC.
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