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ADV PART 2A

Tvamp, LLC (CRD 160321), brochure dated September 27, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.

View firm on SEC ↗ · Current Form ADV (PDF) ↗

ADV PART 2A FIRM BROCHURE For Clients and Prospective Clients September 22, 2026 6025 Brookvale Lane, Suite 160 Knoxville, TN 37919 (865) 226-9982 This disclosure brochure provides information about the qualifications and business practices of TVAMP LLC (also referred to as we, us and TVAMP throughout this disclosure brochure). If you have any questions about the contents of this disclosure brochure, please contact Jeff B. Foster at (865) 226- 9982 or jeff.foster@tvamp.com. The information in this disclosure brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about TVAMP is also available on the SEC’s website at www.adviserinfo.sec.gov. You can view our firm’s information on this website by searching for TVAMP, LLC or our firm’s CRD number 160321. Registration as an investment advisor does not imply a certain level of skill or training. TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 1 Item 2 – Material Changes TVAMP encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you have with the Advisor. Since our last annual updating amendment filed on March 18, 2026, TVAMP has made the following changes: Management of Held-Away Accounts (Pontera) TVAMP has added disclosure regarding the management of certain client assets held in accounts at outside custodians or recordkeepers where TVAMP does not have a direct custodial relationship ("held-away accounts"), such as employer-sponsored retirement plan accounts. TVAMP uses Pontera, a third-party order management platform, to facilitate the review, monitoring and trading of held-away accounts. Items 4, 5, 8, 12, 13, 15 and 16 have been updated to describe the service, the associated fees and billing practices, custody considerations and related risks. Use of Sub-Advisers TVAMP has added disclosure regarding the engagement of unaffiliated registered investment advisers to serve as sub-advisers for certain client accounts, including accounts maintained at qualified custodians other than LPL Financial or Charles Schwab. Items 4, 5, 10, 12, 14 and 16 have been updated to describe these arrangements and the related conflicts of interest. Termination of Asset Management Services TVAMP has added disclosure in Item 5 describing how asset management services terminate and how advisory fees are handled for terminating accounts, including when advisory fees stop accruing, the option to direct an immediate stop, the proration and refund of prepaid fees, and the treatment of accounts transferred without written notice. Item 5 has also been updated to describe termination of retirement plan advisory agreements and the arrears billing treatment on termination. Item 5 also describes the termination and refund treatment for financial planning and consulting services. We will ensure that you receive a summary of material changes, if any, to this and subsequent disclosure brochures within 120 days after our fiscal year ends. Our fiscal year ends on December 31 so you will receive the summary of material changes, if any, no later than April 30 each year. At that time, we will also offer a copy of the most current disclosure brochure. We may also provide other ongoing disclosure information about material changes as necessary. TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 2 Item 3 – Table of Contents ADV PART 2A FIRM BROCHURE .........................................................................................................................1 Item 2 – Material Changes .....................................................................................................................................2 Item 3 – Table of Contents .....................................................................................................................................3 Item 4 – Advisory Business .....................................................................................................................................4 Item 5 – Fees and Compensation ........................................................................................................................ 15 Item 6 – Performance-Based Fees and Side-By-Side Management.................................................................... 20 Item 7 – Types of Clients ..................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................... 21 Item 9 – Disciplinary Information .......................................................................................................................... 23 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................ 23 Item 12 – Brokerage Practices ............................................................................................................................. 26 Item 13 – Review of Accounts ............................................................................................................................. 31 Item 14 – Client Referrals and Other Compensation ........................................................................................... 32 Item 15 – Custody ................................................................................................................................................ 34 Item 16 – Investment Discretion ........................................................................................................................... 35 Item 17 – Voting Client Securities ........................................................................................................................ 36 Item 18 – Financial Information ............................................................................................................................ 36 TVAMP Customer Privacy Policy Notice ............................................................................................................. 37 Office Locations ................................................................................................................................................... 39 TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 3 Item 4 – Advisory Business TVAMP is an investment advisor registered with the U.S. Securities and Exchange Commission and is a limited liability company (LLC) formed under the laws of the State of Tennessee. • Luke A. Bowes is a Managing Member of TVAMP. • Perry L. Chesney, Jr. is a Managing Member of TVAMP. Jeffrey B. Foster, Charles J. Sweat, and Scott B. Fisher are Members of TVAMP. • Introduction The investment advisory services of TVAMP are provided to you through an appropriately licensed and qualified individual who is an investment adviser representative of TVAMP (referred to as your investment adviser representative throughout this brochure). Your investment adviser representative may either be an employee or independent contractor of TVAMP. Your investment adviser representative is limited to providing the services and charging investment advisory fees in accordance with the descriptions detailed in this brochure. However, the exact services you will receive and the fees you will be charged are dependent upon your investment adviser representative and your geographic location. Description of Advisory Services The following are descriptions of the primary services of TVAMP. Please understand that a written agreement, which details the exact terms of the service, must be signed by you and TVAMP before we can provide you with the services described below. Asset Management Services – TVAMP offers asset management services, which involves TVAMP providing you with continuous and on-going supervision over your specified accounts. You must appoint our firm as your investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. The Account is managed by us based on your financial situation, investment objectives and risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments in the Account. We will need to obtain certain information from you to determine your financial situation and investment objectives. Accounts are therefore managed on the basis of your individual financial situation and investment objectives. We encourage clients, at least quarterly, to notify us whether your financial situation or investment objectives have changed, or if you want to impose and/or modify any reasonable restrictions on the management of your accounts. At least annually, we contact individual clients to determine whether their financial situation or investment objectives have changed, or if the client wants to impose and/or modify any reasonable restrictions on the management of accounts managed. We are always reasonably available to consult with individual clients relative to the status of their accounts. You TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 4 have the ability to impose reasonable restrictions on the management of your accounts, including the ability to instruct us not to purchase certain securities. It is important that you understand that we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions we take for you. We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts. Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. Retirement Plan Rollover Recommendations – TVAMP does not recommend rollovers to our clients or prospects. The firm’s activities will be strictly limited to educating clients and prospects as to their options. Should you decide to engage TVAMP to provide investment advice to you regarding your retirement plan account or individual retirement account, we become 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. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 5 Management of Held-Away Accounts (Pontera) – TVAMP may, at its discretion, manage certain client accounts that are maintained at custodians or recordkeepers with which TVAMP does not have a direct custodial relationship ("held-away accounts"). Examples of held-away accounts include employer- sponsored retirement plan accounts, such as 401(k) and 403(b) accounts, and certain 529 plan and health savings accounts. To manage held-away accounts, TVAMP uses Pontera, a third-party order management platform, which allows us to view the account, review current allocations, and implement transactions. To enable this service, you must agree to Pontera's end user terms and conditions and privacy policy, which authorize TVAMP to manage the designated held-away account(s) through the Pontera platform. Once an account is connected through a secure link that you establish, we are able to review the account and, when deemed appropriate and consistent with your investment objectives and risk tolerance, rebalance the account or adjust holdings. Investment selections for held-away accounts are limited to the investment options made available within the account (for example, the fund lineup selected by your employer's plan sponsor), and transactions are subject to any trading restrictions imposed by the plan or account provider. When you engage TVAMP to manage held-away accounts via Pontera, it is your responsibility to: establish and maintain the secure connection for your account(s) through the Pontera platform; keep your usernames and passwords for the held-away accounts up to date within the Pontera system; and promptly address any requests from the Pontera system to update your login credentials. For your security, you should never provide your held-away account login credentials directly to TVAMP or your investment adviser representative. If you delay in updating login credentials, TVAMP will not be able to view or manage the held-away account, which may result in missed rebalancing opportunities, investment losses, or account valuations that are not current being used for reporting or billing purposes. TVAMP is not responsible for delays or losses caused by outdated credentials or a failure to maintain the account connection. If we determine that an account link has become inactive, we will use reasonable efforts to notify you so the issue can be resolved. (Please refer to Item 5 for the fees that apply to held-away accounts, Item 15 for custody- related information and Item 16 for a description of our trading authority over held-away accounts.) Financial Planning & Consulting Services – TVAMP offer financial planning services that can involve preparing a written financial plan covering specific or multiple topics. We can provide full written financial plans, which typically address the following topics: Investment Planning, Retirement Planning, Insurance Planning, Education Planning, Tax Planning, Portfolios Review, and Asset Allocation. Under this program, the role of your investment adviser representative as a financial planner is to find ways to help you understand your overall financial situation and help you set financial objectives. We also provide modular financial plans which only cover those specific areas of concern mutually agreed upon by you and us. A modular written financial plan is limited or segmented and does not involve the creation of a full written financial plan. You should be aware that other important issues may not be taken into consideration when your investment adviser representative develops his or her analysis and recommendations under a modular written financial plan. Written financial plans prepared by us under this Agreement do not include specific recommendations of individual securities. We also offer consultations in order to discuss financial planning issues when you do not need a written financial plan. We offer a one-time consultation, which covers mutually agreed upon areas of concern related to investments or financial planning. We also offer “as-needed” consultations, which are limited TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 6 to consultations in response to a particular investment or financial planning issue raised or request made by you. Under an “as-needed” consultation, it will be incumbent upon you to identify those particular issues for which you are seeking our advice or consultation on. In addition to these services, we offer ongoing advisement consultations to participants in retirement plans (401(k) plans, profit sharing plans, etc.). When providing these services, we review your financial situation, goals and objectives as well as the investment options available in the retirement plan. We will review your retirement plan account at semi-annually intervals and will make such recommendations from the list of available investment options in your retirement plan account as are deemed appropriate and consistent with your stated investment objectives and risk tolerance. These services do not constitute asset management services for your retirement plan account; we do not have investment discretion or trading authority over your retirement plan account. You determine whether or not to implement our advice. The implementation of any trades in your retirement plan account is your responsibility. for determining whether to implement our Our financial planning and consulting services do not involve implementing any transaction on your behalf or the active and ongoing monitoring or management of your investments or accounts. You have the sole financial planning and consulting responsibility recommendations. To the extent that you would like to implement any of our investment recommendations through TVAMP or retain TVAMP to actively monitor your investments, you must execute a separate written agreement with TVAMP for our asset management services. Estate Planning TVAMP may utilize third-party software platforms and service providers to assist clients with estate planning organization, document preparation support, and coordination with estate planning professionals. TVAMP may gather and organize relevant documents and information to assist clients with the creation or updating of estate planning materials. Fees associated with estate planning services are separate from financial planning or advisory fees and are disclosed in Item 5 – Fees and Compensation. Referral of Third-Party Money Managers TVAMP offers advisory services by referring clients to a third-party money manager offering asset management and other investment advisory services. The third-party managers are responsible for continuously monitoring client accounts and making trades in client accounts when necessary. As a result of the referral, we are paid a portion of the fee charged and collected by the third-party money managers in the form of solicitor fees. Each solicitation arrangement is performed pursuant to a written solicitation agreement and is in compliance with SEC Rule 206(4)-1 and applicable state securities rules and regulations. Under this program, we assist you with identifying your risk tolerance and investment objectives. We recommend outside money managers in relation to your stated investment objectives and risk tolerance, and you may select a recommended third-party money manager or model portfolio based upon your needs. You must enter into an agreement directly with the third-party money manager who provides your designated account with asset management services. We are available to answer questions that you may have regarding your account and act as the communication conduit between you and the third-party money manager. The third-party money manager may take discretionary authority to determine the securities to be purchased and sold for you. We do not have any trading authority with respect to your designated account managed by the outside TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 7 money manager. Although we review the performance of numerous third-party investment advisor firms, we enter into only a select number of relationships with third-party investment advisor firms that have agreed to pay us a portion of the overall fee charged to our clients. Therefore, TVAMP has a conflict of interest in that it will only recommend third-party investment advisors that will agree to compensate us for referrals of our clients. Clients are advised that there may be other third-party managed programs, not recommended by our firm, that are suitable for the client and that may be more or less costly than arrangements recommended by our firm. No guarantees can be made that a client’s financial goals or objectives will be achieved by a third-party investment advisor recommended by our firm. Further, no guarantees of performance can ever be offered by our firm (please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more details). Use of Sub-Advisers – In addition to referring clients to third-party money managers as described above, TVAMP may engage unaffiliated registered investment advisers to serve as sub-advisers for certain client accounts. When TVAMP engages a sub-adviser, you remain a client of TVAMP: we are responsible for the overall management of the relationship, including determining that the sub-adviser and the selected model or strategy are appropriate for you, monitoring the sub-adviser's services, and periodically reviewing your account. Sub-advisers are engaged under written agreements with TVAMP and implement transactions in your account (such as trade execution, rebalancing and tax-loss harvesting) in accordance with the model or strategy TVAMP selects, including model portfolios designed by unaffiliated asset managers. A sub- adviser may also be engaged to manage accounts maintained at a qualified custodian with which TVAMP does not have a direct relationship (such as Fidelity). Certain sub-advisers may also act as promoters and provide client referrals to TVAMP under a separate arrangement described in Item 14. You will be provided with a copy of a sub-adviser's Form ADV Part 2A disclosure brochure where required. Please refer to Item 5 for a description of fees related to sub-advisory arrangements and Item 10 for related conflicts of interest. LPL Financial Sponsored Advisory Programs TVAMP may provide advisory services through certain programs sponsored by LPL Financial LLC (LPL), a registered investment advisor and broker-dealer. Below is a brief description of each LPL advisory program available to TVAMP. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs please see the program account packet (which includes the account agreement and LPL Form ADV program brochure) and the Form ADV, Part 2A of LPL or the applicable program. Manager Access Select Program Manager Access Select provides clients access to the investment advisory services of professional portfolio management firms for the individual management of client accounts. The advisor will assist the client in identifying a third-party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made available by LPL. The Portfolio Manager manages a client’s assets on a discretionary basis. The advisor will provide initial and ongoing assistance regarding the Portfolio Manager selection process. TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 8 A minimum account value of $100,000 is most commonly required for Manager Access Select, however, in certain instances, the minimum account size may be as little as $25,000 and as high as $250,000. Optimum Market Portfolios We have entered into an arrangement with LPL to provide services through the Optimum Market Portfolios Program (“OMP”), a wrap-fee program sponsored by LPL. If you contract for this service, you must establish a brokerage account through LPL which serves as the broker/dealer and qualified custodian. OMP offers clients the ability to participate in a professionally managed asset allocation program using OMP Funds Class I shares. We obtain your necessary financial data and assist you in determining the suitability of OMP and in setting an appropriate investment objective. We assist you with opening an account and determining an investment portfolio. Once the program minimum has been reached and a portfolio selected, LPL purchases OMP funds in amounts appropriate for the portfolio selected. LPL is responsible for rebalancing the account on the frequency selected jointly by you and us. There are several OMP funds that may be purchased within an OMP account. LPL follows a strategic asset allocation investment style in constructing portfolios for OMP clients. Asset allocation methodology is implemented by combining investments representing various asset classes that reflect differently to varying market conditions. Thus, if one asset class reacts negatively to certain market events, the potential exists for another asset class to react positively. However, there is no guarantee that the use of an asset allocation strategy will produce favorable results. We are responsible for providing you with information about the investment strategy and the portfolios selected for you. LPL will directly provide you with quarterly account statements (monthly when activity occurs in the account), confirmations and performance reports. Model Wealth Portfolios We have an arrangement with LPL to provide services through the Model Wealth Portfolios (“MWP”) program, a wrap-fee program sponsored by LPL. If you contract for this service, you must establish a brokerage account through LPL which serves as the broker/dealer and qualified custodian. MWP offers clients a professionally managed mutual fund asset allocation program in which LPL, in its capacity as an investment advisor, directs and manages specified client assets. A minimum account value of $25,000 is required for MWP. We obtain your necessary financial data and assist you in determining the suitability of MWP and in setting an appropriate investment objective. We assist you in opening an account and determining an investment portfolio designed by LPL’s Research Department. LPL’s Research Department is responsible for selecting the mutual funds within a portfolio and for making changes to the mutual funds selected. In certain cases, a portfolio may consist only of mutual funds within the same fund family. In such a portfolio, LPL’s Research Department will select only those mutual funds within the fund family. You must grant TVAMP discretionary authority to select the portfolios suitable for you and must grant LPL discretionary authority to select investments held within portfolios and rebalance positions within the portfolios. LPL follows a dynamic asset allocation investment style in constructing portfolios for MWP clients. Asset allocation methodology is implemented by combining investments representing various asset classes that TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 9 respond differently to varying market conditions. Thus, if one asset class reacts negatively to certain market events, the potential exists for another asset class to react positively. However, there is no guarantee that the use of an asset allocation strategy will produce favorable results. We are responsible for providing you with information about the investment strategy and the portfolios selected for you. You receive quarterly account statements (monthly when activity occurs in the account), confirmations, and performance reports directly from LPL. Variable Sub-Account Management Services – Under our sub-account management services, TVAMP manages your variable annuity contract by selecting, monitoring and exchanging as necessary between sub-accounts available from the insurance company issuing the variable annuity contract. Under this program, we work with you to understand your financial goals, investment objectives, time horizon, and risk tolerance. . You will have the opportunity to list on your investment advisory agreement with our firm any reasonable restrictions on the sub-accounts that may be utilized by TVAMP. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however, we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. Once you have provided us with the necessary information and made the appropriate authorizations, TVAMP utilizes trading authority to place the transactions as directed by you. TVAMP may utilize signal providers for guidance regarding investment strategies, asset allocations and timing of exchanges. TVAMP will monitor your sub-accounts and exchange sub-accounts as necessary and in accordance with your investment objective and risk tolerance. Newsletters TVAMP occasionally prepares general, educational, and informational newsletters. Newsletters are always offered on an impersonal basis and do not focus on the needs of a specific individual. Seminars TVAMP may occasionally provide seminars in areas such as financial planning, retirement planning, estate planning, college planning and charitable planning. Seminars are always offered on an impersonal basis and do not focus on the individual needs of participants. Workshops TVAMP offers educational, informative and motivational workshops to the public as well as associations, family foundations and employers. Workshops are always offered on an impersonal basis and do not focus on the individual needs of the participants. Non-Discretionary Investment Consulting TVAMP offers limited, non-discretionary investment consulting services to Clients who do not seek ongoing portfolio management or other investment advisory services referenced in this brochure. These services are designed for Clients who wish to retain full control over their investment decisions and are offered advice solely in response to specific Client-initiated requests. TVAMP reserves the right to waive applicable minimums and fees at its sole discretion. If a client later desires ongoing investment advisory services or portfolio management, a separate written agreement under TVAMP’s standard Investment TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 10 Advisory Services Agreement or Financial Plan Agreement is required. Accounting Liaison Services If selected by the client, TVAMP will provide Accounting Liaison Services. These services will only be provided to clients who have hired TVAMP to provide Asset Management Services. These services may include: • Selection of TVAMP Tax Planning LLC (“TVAMP Tax”) for preparation and filing of client tax returns; • Compiling relevant information to send to TVAMP Tax; • Meeting with TVAMP Tax and the client as needed to discuss the client situation and relevant specific information; Implementation of tax strategies; and • • Review of tax returns prepared by TVAMP Tax. All clients who select TVAMP to provide Accounting Liaison Services will be required to sign an Addendum to the TVAMP Asset Management Agreement setting forth the exact accounting liaison services to be provided. TVAMP is not licensed to provide specific tax advice and hires TVAMP Tax as needed to provide tax services for TVAMP clients. For more information on TVAMP Tax, please see Item 10 of this Brochure. Educational Activities and Social Media Certain investment adviser representatives of TVAMP may engage in educational activities outside of their role with the firm. For example, an investment adviser representative may be employed as a university professor and teach courses related to personal finance or other financial topics. Such employment is separate from the advisory services provided by TVAMP. TVAMP does not compensate any university or educational institution for referrals, and the university does not endorse or sponsor TVAMP’s advisory services. Any advisory relationship is established solely through a separate written agreement between the client and TVAMP. From time to time, TVAMP may advertise in university publications or communicate with individuals who independently express interest in learning more about the firm’s services. Educational presentations, workshops, or similar events are provided for general informational purposes only and do not constitute individualized investment advice. In addition, certain supervised persons of TVAMP may maintain personal websites, blogs, podcasts, or social media channels (including video-sharing platforms) that provide general educational content related to investing, financial planning, or retirement planning. TVAMP may review and republish such content through the firm’s own marketing channels. All such communications are intended for general informational purposes and are not tailored to the needs of any specific individual. Because investment adviser representatives are compensated based in part on advisory fees generated from client relationships, they have a financial incentive to encourage prospective clients, including individuals who learn about TVAMP through educational activities or social media, to engage the firm’s TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 11 advisory services. This presents a conflict of interest. TVAMP addresses this conflict through its fiduciary duty to act in the best interests of clients and through supervisory oversight of marketing communications. Retirement Plan Advisory Services (ERISA 3(21) and 3(38)) TVAMP provides advisory services to employer-sponsored retirement plans, including both non- discretionary ERISA §3(21) fiduciary services and discretionary ERISA §3(38) investment management services. These services are offered pursuant to written agreements entered into with the plan sponsor. The scope of services varies by engagement and is described in the applicable agreement. Under a 3(21) non-discretionary engagement, TVAMP assists the plan sponsor with the development and review of the plan’s investment policy statement (“IPS”), provides recommendations regarding investment options, assists with monitoring investment performance, and provides general investment education to plan participants. The plan sponsor retains full authority and responsibility for selecting, removing, or replacing investment options. Under a 3(38) discretionary engagement, TVAMP has full discretionary authority to select, monitor, and replace the plan’s investment options in accordance with the IPS. TVAMP may also direct the plan’s recordkeeper to rebalance model portfolios or investment option allocations. The plan sponsor retains responsibility for ongoing oversight of TVAMP and compliance with ERISA Section 404(c), if applicable. In both programs, TVAMP may also provide non-fiduciary services, such as general investment education and group enrollment meetings, which do not involve individualized advice to plan participants. TVAMP does not provide legal, tax, or actuarial advice and does not act as the plan administrator or trustee. Limits Advice to Certain Types of Investments Although we generally provide advice on Mutual Funds and Exchange Traded Funds, we reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. TVAMP provides investment advice on the following types of investments: Interests in Partnerships Investing in Real Estate Interests in Partnerships Investing in Oil and Gas Interests • Mutual Funds • Exchange Traded Funds (ETFs) • Exchange-listed Securities • Securities Traded Over-the-Counter • Foreign Issues • Warrants • Corporate Debt Securities • Commercial Paper • Certificates of Deposit • Municipal Securities • Variable Annuities that have been approved for inclusion in the LPL Platform • US Government Securities • Options Contracts on Securities • • • Collective Investment Trusts and other investment options available within employer-sponsored TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 12 retirement plans Different fund categories have different risk characteristics and investors should not compare different categories. For example, a bond fund and a stock fund that both have below average risk still have different risk/return potential (stock funds traditionally have higher risk/return potential). Risks are based on the investments held in the fund. For example, a bond fund faces interest rate risk and income risk, and income is affected by the change in interest rates. A sector fund (investing in a single industry) is at risk that its price will decline due to industry developments. The following are risks to consider when investing in mutual funds: • Call Risk: A bond issuer may redeem high-yield bonds before maturity date due to falling interest rates. • Default Risk: A bond issuer may fail to repay interest and principal. • Income Risk: Dividends in a fixed income fund may decline due to falling interest rates. • Geology Risk: Political events, natural disasters or financial problems may weaken a country • • or state’s economy and cause investments to decline. Industry Risk: Stocks in a single industry may decline due to developments in that industry. Inflation Risk: Increases in the cost of living can reduce or eliminate a fund’s actual returns when adjusted for inflation. • Manager Risk: A manager may not execute the fund’s investment strategy in a timely or effective manner. When providing asset management services, TVAMP typically constructs each client’s account holdings using Exchange Traded Funds and Mutual Funds to build diversified portfolios. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. You have the ability to place reasonable restrictions on the types of investments that may be purchased in your account. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Participation in Wrap Fee Programs TVAMP offers services through both wrap-fee programs and non-wrap fee programs. A wrap fee program is defined as any advisory program under which a specified fee or fees not based directly upon transactions in a client’s account is charged for investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions. Whenever a fee is charged to a client for services described in this brochure (whether wrap fee or non-wrap fee), we will receive all or a portion of the fee charged. WRAP Fee Program Disclosure As representative of LPL Financial, LLC, the investment advisor representatives of TVAMP have the ability to offer WRAP account services conducted though the LPL SWM-ADV program. Although clients do not pay a transaction charge for transactions in a SWM-ADV account, clients should be aware that TVAMP pays LPL transaction charges for those transactions. The transaction charges paid by TVAMP vary based on the type of transaction (e.g., mutual fund, equity or ETF) and for mutual funds based on whether or not the mutual fund pays 12b-1 fees and/or recordkeeping fees to LPL. Transaction charges TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 13 paid by the Advisor for equities are $7 and ETFs are $0-$9. For mutual funds, the transaction charges range from $0 to $26.50. Because TVAMP pays the transaction charges in SWM-ADV accounts, there is a conflict of interest in cases where the mutual fund is offered at both $0 and $26.50. Clients should understand that the cost to Advisor of transaction charges may be a factor that TVAMP considers when deciding which securities to select and how frequently to place transactions in a SWM-ADV account. In many instances, LPL makes available mutual funds in a SWM-ADV account that offer various classes of shares, including shares designated as Class A Shares and shares designed for advisory programs, which can be titled, for example, as “Class I,” “institutional,” “investor,” “retail,” “service,” “administrative” or “platform” share classes (“Platform Shares”). The Platform Share class offered for a particular mutual fund in SWM-ADV in many cases will not be the least expensive share class that the mutual fund makes available and was selected by LPL in certain cases because the share class pays LPL compensation for the administrative and recordkeeping services LPL provides to the mutual fund. Client should understand that another financial services firm may offer the same mutual fund at a lower overall cost to the investor than is available through SWM-ADV. In other instances, a mutual fund may offer only Class A Shares, but another similar mutual fund may be available that offers Platform Shares. Class A Shares typically pay LPL a 12b-1 fee for providing shareholder services, distribution, and marketing expenses (“brokerage- related services”) to the mutual funds. Platform Shares generally are not subject to 12b-1 fees. As a result of the different expenses of the mutual fund share classes, it is generally more expensive for a client to own Class A Shares than Platform Shares. An investor in Platform Shares will pay lower fees over time and keep more of his or her investment returns than an investor who holds Class A Shares of the same fund. Other financial services firms may offer the same mutual fund at a lower overall cost to the investor than is available through the LPL Programs. TVAMP has a financial incentive to recommend Class A Shares in cases where both Class A and Platform Shares are available. This is a conflict of interest which might incline TVAMP, consciously or unconsciously, to render advice that is not disinterested. Although the client will not be charged a transaction charge for transactions, Advisor pays LPL a per transaction charge for mutual fund purchases and sales in the account. TVAMP generally does not pay transaction charges for Class A Share mutual fund transactions accounts but generally does pay transaction charges for Platform Share mutual fund transactions. The cost to TVAMP of transaction charges generally may be a factor Advisor considers when deciding which securities to select and whether or not to place transactions in the account. Tailor Advisory Services to Individual Needs of Clients TVAMP’s services are always provided based on your individual needs. This means, for example, that you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. Our financial planning and consulting services are always provided based on your individual needs. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. However, we will not enter into an investment advisor relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. When managing client accounts through our firm’s Asset Management Services program, we may manage a client’s account in accordance with one or more investment models. When client accounts are managed using models, investment selections are based on the underlying model and we do not develop TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 14 customized (or individualized) portfolio holdings for each client. However, the determination to use a particular model or models is always based on each client’s individual investment goals, objectives and mandates. Client Assets Managed by TVAMP The amount of client’s assets managed by us totaled $1,185,099,837 as of December 31, 2025 $1,174,287,250 is managed on a discretionary basis and $10,812,581 is managed on a non-discretionary basis. Item 5 – Fees and Compensation TVAMP provides ongoing investment management services for client accounts. These services include providing continuous investment advice, portfolio management, and monitoring of client accounts based on the client’s financial circumstances, investment objectives, and risk tolerance. Fees for asset management services are generally based on a percentage of assets under management and are billed quarterly in advance based on the value of the account as of the last business day of the prior calendar quarter. Fees are prorated for accounts opened or terminated during a billing period. Termination of Asset Management Services You may terminate asset management services at any time by providing written notice to TVAMP. Your written notice begins a wind-down period during which TVAMP remains the investment adviser of record on your account and continues to provide services, including monitoring the account and assisting with liquidations, raising cash, and transfer paperwork. Advisory fees continue to accrue during the wind- down period and stop on the earliest of the date your assets transfer out of the account, the date the account is deactivated with the qualified custodian, or seven (7) days after TVAMP receives your written notice. You may instead direct TVAMP in writing to cease services immediately, in which case your account will be deactivated and advisory fees will stop as of that date. If TVAMP terminates services by providing written notice to you, advisory fees stop as of the effective date stated in TVAMP’s notice. Account deactivation is processed by the qualified custodian, and processing generally takes one to three business days from TVAMP’s deactivation request; the deactivation date is determined by the custodian’s processing procedures, not by TVAMP. In all cases, advisory fees stop no later than seven (7) days after TVAMP receives your written notice, and any prepaid fees for the period after fees stop are refunded as described below. Because advisory fees are billed in advance, any fees paid for the period after fees stop are prorated and refunded, generally through a credit applied to your account as part of the custodian’s fee adjustment process or, if your account has been closed or transferred before a credit can be applied, by direct payment to you. If you transfer your account without providing written notice (for example, by initiating a transfer to another financial institution), advisory fees stop when the assets transfer out of the account, and any prepaid fees for the period after that date are prorated and refunded in the same manner. Custodial, program, platform, and fund-level fees charged by parties other than TVAMP are not advisory fees and may continue to accrue until your account is closed or deactivated. For accounts custodied at LPL Financial, advisory fee calculations are performed through the custodian’s billing system based on the client’s written authorization. Because fee calculations are performed at the custodial level, TVAMP does not manually adjust account values for billing purposes. TVAMP reviews advisory fee calculations for reasonableness and accuracy as part of its supervisory process. The maximum annual advisory fee for asset management services is 2.00% of assets under management. TVAMP generally requires a minimum account size of $50,000, although this minimum may be waived at TVAMP’s discretion. TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 15 Asset Management Services TVAMP may charge advisory fees based on one of the following methods, as specified in the client agreement. Tiered Asset-Based Fee Schedule Account Value Maximum Annual Fee First $100,000 Up to 2.00% Next $200,000 Up to 1.75% Next $450,000 Up to 1.50% Next $750,000 Up to 1.25% Assets above $1,500,000 Up to 1.00% TVAMP may also charge a flat annual fee or flat dollar fee, depending on the services provided and the agreement with the client. A minimum fee or fixed quarterly fee may apply in certain circumstances, as set forth in the client agreement. Clients authorize the qualified custodian of their account to deduct advisory fees directly from the account. Held-Away Accounts Managed via Pontera Fees for the management of held-away accounts are calculated in accordance with the asset management fee schedule described above (or as otherwise set forth in your client agreement) based on the value of the held-away account(s). Because TVAMP cannot deduct advisory fees directly from a held-away account, fees attributable to held-away accounts will either be deducted, pursuant to your written authorization, from another account you maintain with TVAMP at a qualified custodian (for example, an account custodied at LPL Financial or Charles Schwab & Co., Inc.) or billed directly to you, as set forth in your client agreement. For fees deducted from an account custodied at LPL Financial, the deduction is processed through LPL’s fee billing system pursuant to your written authorization. When fees for a held-away account are deducted from a different account, the deduction reduces the value of the account from which the fee is paid, and you should consider the source of payment (including any tax considerations) when authorizing this billing method. Account values used for billing purposes are obtained through the Pontera platform. If the connection to a held-away account becomes inactive (for example, due to outdated login credentials), fees may be calculated using the most recent valuation available to TVAMP in good faith. TVAMP pays Pontera a platform fee for the use of the Pontera technology; this fee is paid by TVAMP and is not an additional charge to clients. Because managing held-away accounts increases the assets on which TVAMP charges advisory fees, TVAMP has a financial incentive to recommend that clients add held-away accounts to this service. TVAMP addresses this conflict through its fiduciary duty to act in your best interest and by recommending the service only where ongoing management of the account is appropriate for you. Wrap Fee Program TVAMP sponsors the TVAMP Asset Management Program, a wrap fee program offered through LPL Financials’ Strategic Wealth Management platform. Under the wrap fee program, clients pay a single asset-based fee that includes investment advisory services and most transaction costs associated with the account. Because wrap fees include transaction costs, clients may pay more or less than they would in a traditional brokerage account depending on the level of trading activity. The maximum annual advisory fee for the wrap fee program is 2.00% of assets under management, although the actual fee charged is negotiable and disclosed in the client agreement. TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 16 Additional information regarding the wrap fee program is provided in the TVAMP Wrap Fee Program Brochure (Form ADV Part 2A Appendix 1). LPL Advisory Programs TVAMP may recommend advisory programs sponsored by LPL Financial. Fees for these programs vary depending on the specific program selected and may include a combination of program fees, strategist fees, and adviser fees. Maximum program fees are generally as follows: Manager Access Select Optimum Market Portfolios Personal Wealth Portfolios Model Wealth Portfolios Guided Wealth Portfolios 2.5% 2.5% 2.5% 2.6%* 1.35%* * Detailed information regarding each program, including fee structures and conflicts of interest, is provided in the applicable LPL program brochure, which clients receive prior to enrolling in the program. TVAMP receives compensation when clients participate in LPL-sponsored advisory programs, and the amount of compensation varies depending on the program selected. These differences are based on the fee structure of each program and the associated arrangements with LPL. As a result, TVAMP may receive higher compensation from certain programs than from others or than from other advisory arrangements. This creates a financial incentive for TVAMP to recommend programs that result in higher compensation. TVAMP addresses this conflict through its fiduciary duty to act in the client’s best interest and through supervisory review of investment recommendations. Other Fees and Expenses In addition to TVAMP’s advisory fees, clients may incur other fees and expenses associated with investment products and brokerage services. These may include brokerage transaction charges, mutual fund or ETF expenses, variable annuity fees, retirement plan administration fees, custodial charges, and other account- related expenses. Certain mutual funds charge distribution or servicing fees commonly referred to as 12b-1 fees. These fees are paid from the assets of the mutual fund and are described in the fund’s prospectus. Investment adviser representatives of TVAMP are also registered representatives of LPL Financial LLC (“LPL”), a broker-dealer. In that capacity, LPL receives 12b-1 fees associated with certain mutual fund share classes. Although these fees are not paid directly to TVAMP, a portion of the compensation LPL receives is shared with its registered representatives pursuant to its compensation structure. As a result, TVAMP’s investment adviser representatives receive an indirect financial benefit from such fees... This arrangement creates a potential conflict of interest because it provides an incentive to recommend investment products or share classes that generate additional compensation. TVAMP addresses this conflict through its fiduciary duty to act in the client’s best interest and through supervisory oversight of investment recommendations. Clients should review the prospectus or offering documents for any investment product to understand the fees and expenses associated with that investment. TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 17 Accounting Liaison Services Prior to engaging us to provide Accounting Liaison Services, the client is required to sign an Addendum to the TVAMP Asset Management Agreement setting forth the terms and conditions, including the fees charged for Accounting Liaison Services. Annual fees charged for our Accounting Liaison Services range up to 1% of assets under management with TVAMP. Fees are billed in advance (at the start of the billing period) on a quarterly calendar basis and calculated based on the fair market value of your account as of the last business day of the previous billing period. Any Accounting Liaison Fee is separate from and in addition to any Advisory Fee paid to TVAMP. The total fee paid to TVAMP will never exceed 2% of assets under management with TVAMP. Fees are negotiable based upon the type of client, the services requested, the complexity of the client’s situation, the composition of the client’s account, other advisory services provided and the relationship of the client and TVAMP. Retirement Plan Advisory Fees TVAMP charges asset-based or fixed fees for retirement plan services, as described in the service agreement with the plan sponsor. Fees may be billed directly to the plan sponsor or deducted from plan assets by the plan’s recordkeeper. Fees are billed in arrears based on the value of included plan assets at the end of the billing period. Either party may terminate a retirement plan advisory agreement upon thirty (30) days prior written notice to the other party, as provided in the agreement. If the agreement is terminated mid-period, fees are prorated through the effective date of termination. Any unearned prepaid fees are refunded within fourteen (14) business days, as stated in the agreement. Because retirement plan fees are billed in arrears, prepaid fees are not expected and refunds should rarely be necessary. TVAMP does not expect to receive compensation other than the fees described in the agreement. If any additional compensation is received (e.g., from recordkeepers or investment providers), TVAMP will offset the compensation against its stated fees and disclose the source of the compensation in accordance with ERISA Regulation §2550.408b-2. Financial Planning & Consulting Services TVAMP offers financial planning and consulting services under several fee arrangements depending on the scope of services provided. Hourly Fees Financial planning services may be provided under an hourly arrangement at hourly rates ranging from $100 per hour for administrative services to $500 per hour for investment adviser representative services. Fixed Fees TVAMP may charge a fixed fee for financial planning engagements. Fixed fees generally range from $500 to $8,000, depending on the complexity of the engagement. Annual Financial Planning Fees TVAMP may provide ongoing planning services for retirement accounts for a fee of up to 2.00% of assets under advisement, billed quarterly in arrears. Subscription Services TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 18 TVAMP may offer ongoing financial consulting services through a subscription arrangement. Subscription fees may range up to $8,000 annually, billed monthly or as otherwise agreed with the client. The specific fee arrangement for financial planning services will be described in the client agreement. Financial planning and consulting fees may be paid by check, electronic funds transfer, or credit card, as agreed with the client and set forth in the client agreement. You may terminate financial planning or consulting services at any time by providing written notice to TVAMP. If you terminate within five (5) business days of entering into the agreement, no fees are due. If you terminate after five (5) business days, you are responsible for fees for services performed through the date TVAMP receives your notice, and any remaining balance of fees paid in advance will be refunded to you. For consulting services charged as a percentage of assets under advisement, fees are prorated through the effective date of termination and any unearned prepaid fees are refunded. Third-Party Money Managers TVAMP may recommend that clients engage the services of third-party investment managers (“Third-Party Managers”) to provide discretionary portfolio management services. In these arrangements, the client enters into a separate agreement directly with the Third-Party Manager, who is responsible for managing the client’s account and making investment decisions in accordance with the client’s investment objectives, risk tolerance, and financial circumstances. TVAMP assists clients with evaluating and selecting Third-Party Managers based on factors such as the client’s investment objectives, risk tolerance, account size, investment strategy, and other relevant considerations. Once a Third-Party Manager has been selected, TVAMP remains available to help coordinate communications between the client and the Third-Party Manager and may periodically review the overall performance of the account and the appropriateness of the selected manager. The Third-Party Manager typically has discretionary authority to select the securities to be purchased and sold for the client’s account. TVAMP does not exercise trading authority over accounts managed by Third-Party Managers unless otherwise specified in the client agreement. TVAMP receives a portion of the advisory fee charged by the Third-Party Manager for clients referred by TVAMP. This compensation creates a conflict of interest because TVAMP has a financial incentive to recommend Third-Party Managers that agree to compensate the firm. TVAMP addresses this conflict by recommending Third-Party Managers based on the client’s investment needs and by disclosing the compensation arrangement to clients prior to entering into the advisory relationship. Clients should be aware that there may be other Third-Party Managers available that offer similar services and may charge lower or higher fees. Clients are not obligated to select a Third-Party Manager recommended by TVAMP and may engage other investment advisers independently. Each Third-Party Manager will provide clients with its own Form ADV Part 2A disclosure brochure describing its services, fees, investment strategies, and risks. Clients are encouraged to review these materials carefully before engaging a Third-Party Manager. Sub-Advisory Arrangements When TVAMP engages a sub-adviser to provide services to your account (see Item 4 – Use of Sub-Advisers), you pay TVAMP the advisory fee set forth in your client agreement, and TVAMP compensates the sub- adviser out of the advisory fee it receives, unless otherwise disclosed in your client agreement. The engagement of a sub-adviser does not increase the advisory fee you pay unless disclosed to you in advance. Because the sub-advisory fee reduces the portion of the advisory fee TVAMP retains, TVAMP has a financial incentive to select sub-advisers that charge lower fees. TVAMP addresses this conflict by selecting and monitoring sub-advisers based on the best interests of its clients. TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 19 Variable Sub-Account Management Services TVAMP may provide advisory services to the sub-accounts of certain variable annuity contracts approved for management through LPL Financial. Clients participating in this program pay an advisory fee of up to 2.00% annually, billed quarterly in advance based on the value of the variable annuity contract under management. In addition to the advisory fee charged by TVAMP, the variable annuity issuer charges internal expenses, which may include mortality and expense charges, administrative fees, and underlying investment management fees. If the variable annuity was originally purchased through the investment adviser representative in his or her capacity as a registered representative of a broker-dealer, the representative may have received a commission or trail compensation at the time of sale. This compensation is separate from the advisory fee charged for ongoing management. Services Provided Without Charge TVAMP may provide newsletters, educational materials, and seminars to clients or prospective clients at no charge. Estate Planning TVAMP may assist clients with estate planning coordination and organization of estate planning information. Fees for estate planning services vary depending on the complexity of the engagement and will be disclosed in the client agreement prior to the commencement of services. Clients are not required to utilize any third-party services that may be recommended and may obtain similar services from other professionals. Item 6 – Performance-Based Fees and Side-By-Side Management Performance-based fees are defined as fees based on a share of capital gains on or capital appreciation of the assets held in a client’s account. Item 6 is not applicable to this Disclosure Brochure because we do not charge or accept performance-based fees. Item 7 – Types of Clients TVAMP provides advisory services to Individuals, Entities (including charitable and other non-profit organizations), Pension and Profit-Sharing plans. You will be required to execute a written agreement with TVAMP specifying the particular services in order to establish a client arrangement with TVAMP. Minimum Investment Amounts Required TVAMP requires a minimum of $50,000 in order to open an account. To reach this account minimum, clients can aggregate all household accounts. Exceptions may be granted to this minimum based on the investment adviser representative providing the services, the type of client, the complexity of the client’s situation, the composition of the client’s account, the potential for additional account deposits, and the relationship of the client and the investment adviser representative. TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 20 The minimum fee generally charged for financial planning and consulting services is $500. Third-party money managers may have minimum account and minimum fee requirements in order to participate in their programs. Each-third party money manager will disclose its minimum account size and fees in its Form ADV Part 2A. For sub-account management services, TVAMP generally requires a variable annuity contract with a minimum account value of $50,000. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis TVAMP primarily relies on fundamental analysis and asset allocation principles when providing investment advice. Fundamental analysis involves evaluating factors such as economic conditions, interest rate environments, market trends, and characteristics of specific investments including cost structure, diversification, and historical performance. TVAMP also evaluates third-party investment managers, model portfolios, and investment strategies offered through institutional advisory platforms. When selecting or recommending third-party managers or model portfolios, TVAMP considers factors such as: Investment Philosophy and Process • • Historical Performance • Risk Management Approach • Portfolio Diversification • Cost and Fee Structure The firm may also consider research and analysis provided by institutional research providers, program sponsors, or investment strategists. Investment Strategies TVAMP generally employs long-term investment strategies designed to align client portfolios with their investment objectives, time horizon, and tolerance for risk. Investment recommendations are typically based on strategic asset allocation principles intended to provide diversification across asset classes and investment styles. Client portfolios may include a combination of investments such as individual equity securities (stocks), fixed income securities (bonds), mutual funds, exchange-traded funds (ETFs), model portfolios, and third-party investment managers. In certain cases, portfolios may be managed through advisory programs offered by institutional platform providers or through third-party managers selected based on the client’s objectives and risk profile. TVAMP may recommend diversified portfolios designed to pursue growth, income, capital preservation, or a combination of these objectives. Portfolio allocations may be periodically rebalanced or adjusted based on changes in market conditions, investment opportunities, or changes in a client’s financial circumstances. In some circumstances, client accounts may utilize margin, which allows clients to borrow funds from a TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 21 broker-dealer to purchase securities using the securities in the account as collateral. The use of margin increases both the potential gains and losses of an investment and can increase the volatility of an account. Clients who use margin will incur interest charges and must maintain minimum equity levels in their accounts as required by the broker-dealer. TVAMP does not typically recommend the use of margin as a primary investment strategy; however, margin may be available within certain brokerage accounts depending on the client’s account structure and investment objectives. Clients should carefully consider the risks associated with borrowing before utilizing margin. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. The value of investments may fluctuate due to changes in market conditions, economic developments, interest rates, and other factors that are beyond the control of TVAMP. Clients should understand that investment strategies and investments recommended by TVAMP involve varying degrees of risk and there can be no assurance that any investment strategy will achieve its intended objective. The principal risks associated with the investment strategies used by TVAMP include, but are not limited to, the following: Market Risk The value of securities may fluctuate due to general market conditions, economic developments, geopolitical events, interest rate changes, or changes in investor sentiment. Equity Risk Investments in individual stocks are subject to fluctuations in value due to company-specific developments, earnings changes, industry conditions, or broader market factors. Fixed Income Risk Investments in bonds and other fixed income securities are subject to risks including credit risk, interest rate risk, and the risk that the issuer may fail to meet its payment obligations. Interest Rate Risk When interest rates rise, the value of existing fixed income securities typically declines. Changes in interest rates may also impact the income generated by fixed income investments. Inflation Risk Inflation may reduce the purchasing power of investment returns over time. Manager RiskWhen third-party investment managers, sub-advisers, strategists, or model portfolios are utilized, their investment decisions may not perform as expected, which could result in losses. Held-Away Account and Platform Risk When TVAMP manages held-away accounts through the Pontera order management platform, our ability to monitor and trade the account depends on your maintaining a secure connection and current login credentials, and on the continued availability of the Pontera platform and the account provider's systems. Investment options in held-away accounts are limited to those made available by the plan or account provider, and plan rules (such as trading restrictions and frequent-trading policies) may limit the timing or implementation of transactions. Technology interruptions, connectivity failures, or outdated credentials may delay or prevent trading and may affect the accuracy of account valuations used for reporting and billing. Retirement Plan / ERISA Fiduciary Risk When providing services to retirement plans governed by the Employee Retirement Income Security Act of 1974 (“ERISA”), TVAMP may act as either a non-discretionary fiduciary under ERISA §3(21) or a discretionary investment manager under ERISA §3(38), depending on the agreement with the plan sponsor. In these roles, TVAMP provides investment recommendations or investment management services to the plan. TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 22 Liquidity Risk Certain investments may be difficult to sell quickly without significantly affecting the market price, particularly during periods of market stress. Concentration Risk Portfolios that are concentrated in a particular security, industry, or asset class may experience greater volatility and risk of loss than more diversified portfolios. ETF and Mutual Fund Risk Investments in exchange-traded funds and mutual funds are subject to the risks of the underlying securities held by the fund as well as the investment decisions of the fund manager. These investments also include management fees and other expenses that reduce returns. Margin Risk When securities are purchased on margin, clients borrow funds from a broker-dealer to purchase securities using the securities in the account as collateral. The use of margin magnifies both gains and losses and increases the volatility of the account. If the value of the securities in a margin account declines, the client may be required to deposit additional funds or securities to maintain the required equity level. If a margin call is not met, the broker-dealer may liquidate securities in the account without prior notice. Digital Asset-Linked Investment Risk Certain investment vehicles, such as exchange-traded funds that track bitcoin or other digital asset benchmarks, may provide indirect exposure to digital assets. These investments may experience heightened volatility, regulatory uncertainty, liquidity constraints, and tracking error risk relative to the underlying asset. If those securities in a margin account decline in value, the value of the collateral supporting this loan also declines, and as a result, the brokerage firm is required to take action in order to maintain the necessary level of equity in your account. The brokerage firm may issue a margin call and/or sell other assets in Item 9 – Disciplinary Information Item 9 is not applicable to this Disclosure Brochure because there are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our business or integrity. Item 10 – Other Financial Industry Activities and Affiliations TVAMP is not and does not have a related person that is a broker/dealer, municipal securities dealer, government securities dealer or broker, an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund), another investment adviser or financial planner, a futures commission merchant, commodity pool operator, or commodity trading advisor, a banking or thrift institution, a lawyer or law firm, a pension consultant, a real estate broker or dealer, and a sponsor or syndicator of limited partnerships. We are an independent registered investment registered advisor and only provide investment advisory services. We are not engaged in any other business activities and offer no other services except those described in this Disclosure Brochure. However, while we do not sell products or services other than investment advice, our representatives may sell other products or provide services outside of their role as investment advisor representatives with us. Registered Representative of a Broker-Dealer Our representatives may also be registered representatives of LPL Financial, a securities broker-dealer. You may work with your investment adviser representative in his or her separate capacity as a registered TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 23 representative of LPL Financial. When acting in his or her separate capacity as a registered representative, your investment adviser representative may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange-traded funds, and variable annuity and variable life products to you. As such, your investment adviser representative may suggest that you implement investment advice by purchasing securities products through a commission-based brokerage account in addition to or in lieu of a fee-based investment-advisory account. This receipt of commissions creates an incentive to recommend those products for which your investment adviser representative will receive a commission in his or her separate capacity as a registered representative of a securities broker-dealer. Consequently, the objectivity of the advice rendered to you could be biased. You are under no obligation to use the services of our representatives in this separate capacity or to use LPL Financial and can select any broker/dealer you wish to implement securities transactions. If you select our representatives to implement securities transactions in their separate capacity as registered representatives, they must use LPL Financial. Prior to effecting any transactions, you are required to enter into a new account agreement with LPL Financial. The commissions charged by LPL Financial may be higher or lower than those charged by other broker/dealers. TVAMP Advisor Representatives Other Business Activities – Banking or Thrift Institutions TVAMP has established and will continue to establish marketing arrangements with banks and other depository institutions whereby investment advisory services of TVAMP may be marketed through these banks and other depository institutions, provided that such marketing is done in compliance with applicable SEC and state regulations. Further, TVAMP may have investment adviser representatives conducting business from and/or affiliated with a bank or other depository institution. These relationships may create compliance issues related to consumer protection. Third-Party Money Managers Our representatives are also registered representatives of LPL Financial, a securities broker-dealer. As such TVAMP may utilize Third Party Money managers that have been pre-approved by LPL Financial. This program is designed to allow us to recommend and select third-party money managers for you. Once you select the third-party money manager to manage all or a portion of your assets, the third-party money manager will pay us a portion of the fees you are charged. Please refer to Item 5 for full details regarding the programs, fees, conflicts of interest and materials arrangements when select other investment advisers. Sub-Advisers TVAMP engages unaffiliated registered investment advisers to serve as sub-advisers for certain client accounts, as described in Item 4. Sub-advisers are not affiliated with TVAMP. TVAMP compensates sub- advisers out of the advisory fee TVAMP receives unless otherwise disclosed in the client agreement, and TVAMP does not receive compensation from sub-advisers for selecting or recommending them. A sub- adviser currently engaged by TVAMP separately refers prospective clients to TVAMP under a promoter arrangement described in Item 14, under which TVAMP pays the sub-adviser a portion of the advisory fees received from referred clients. These concurrent relationships create a conflict of interest: TVAMP has an incentive to maintain the sub-advisory relationship in support of the referral relationship, and the sub-adviser has an incentive to refer prospective clients to TVAMP. TVAMP addresses these conflicts by selecting and monitoring sub-advisers based on the best interests of its clients and by disclosing these relationships to you. Insurance Agency/Agents TVAMP is a licensed as an Insurance Agency with the state of Tennessee and Ohio. In January of 2023 TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 24 TVAMP became a licensed Insurance Agency with the State of Georgia. In 2024 TVAMP became licensed as a nonresident Insurance Agency with the State of Texas and Florida. You may work with your investment adviser representative in his or her separate capacity as an insurance agent though the TVAMP agency. When acting in his or her separate capacity as an insurance agent, the investment adviser representative may sell, for commissions, general disability insurance, life insurance, long-term care insurance and annuities to you. As such, your investment adviser representative in his or her separate capacity as an insurance agent, may suggest that you implement recommendations of TVAMP by purchasing disability insurance, life insurance, and long-term care insurance or annuities. This receipt of commissions creates an incentive for the representative to recommend those products for which your investment adviser representative will receive a commission in his or her separate capacity as an insurance agent. Consequently, the advice rendered to you could be biased. You are under no obligation to implement any insurance or annuity transaction through your investment adviser representative. TVAMP Tax TVAMP is affiliated with TVAMP Tax, an accounting firm that prepares tax returns, through common ownership. This is a conflict of interest. TVAMP has an incentive to recommend TVAMP Tax to provide tax services to its clients because it is an affiliate of TVAMP. Additionally, the compensation paid to TVAMP Tax is based on the client’s assets managed by TVAMP. We mitigate this conflict by ensuring the recommendation to use TVAMP Tax is in the clients’ best interest. Educational and Media Activities of Investment Adviser Representatives Certain investment adviser representatives may be employed in non-advisory roles outside of TVAMP, including as university instructors or professors. Compensation received in connection with such employment is limited to teaching services and is not related to advisory services offered by TVAMP. These outside activities may create a conflict of interest to the extent that relationships developed through such roles may result in individuals choosing to engage TVAMP for advisory services. Clients are under no obligation to engage TVAMP as a result of any educational relationship. In addition, certain investment adviser representatives may maintain personal media platforms, including social media or video-sharing channels, that provide general educational content related to financial topics. Any advisory relationship with TVAMP is established solely through a written agreement with the firm. Item 11 – Code of Ethics, Participation in Client Transactions & Personal Trading Code of Ethics Summary An investment advisor is considered a fiduciary and has a fiduciary duty to all clients. TVAMP has established a Code of Ethics to comply with the requirements of the securities laws and regulations that reflect its fiduciary obligations and those of its supervised persons. The Code of Ethics also requires compliance with federal securities laws. TVAMP’s Code of Ethics covers all individuals that are classified as “supervised persons”. All employees, officers, directors and investment advisor representatives are classified as supervised persons. TVAMP requires its supervised persons to consistently act in your best interest in all advisory activities. TVAMP imposes certain requirements on its affiliates and supervised TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 25 persons to ensure that they meet the firm’s fiduciary responsibilities to you. The standard of conduct required is higher than ordinarily required and encountered in commercial business. This section is intended to provide a summary description of TVAMP’s Code of Ethics. If you wish to review the Code of Ethics in its entirety, you should send a written request and upon receipt of your request, a copy of the Code of Ethics will promptly be provided to you. Affiliate and Employee Personal Securities Transactions Disclosure TVAMP or associated persons of the firm may buy or sell for their personal accounts, investment products identical to those recommended to clients. This creates a potential conflict of interest. It is the express policy of TVAMP that all persons associated in any manner with our firm must place clients’ interests ahead of their own when implementing personal investments. TVAMP and its associated persons will not buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by information obtained as a result of employment or association with our firm unless the information is also available to the investing public upon reasonable inquiry. We are now and will continue to be in compliance with applicable state and federal rules and regulations. To prevent conflicts of interest, we have developed written supervisory procedures that include personal investment and trading policies for our representatives, employees and their immediate family members (collectively, associated persons): • Associated persons cannot prefer their own interests to that of the client. • Associated persons cannot purchase or sell any security for their personal accounts prior to implementing transactions for client accounts. • Associated persons cannot buy or sell securities for their personal accounts when those decisions are based on information obtained as a result of their employment, unless that information is also available to the investing public upon reasonable inquiry. • Associated persons are prohibited from purchasing or selling securities of companies in which any client is deemed an “insider.” • Associated persons are discouraged from frequent personal trading. • Associated persons are generally prohibited from serving as board members of publicly traded companies unless an exception has been granted TVAMP’s Chief Compliance Officer. Any associated person not observing our policies is subject to sanctions up to and including termination. Item 12 – Brokerage Practices Clients are under no obligation to act on the financial planning recommendations of TVAMP. If the firm assists in the implementation of any recommendations, we are responsible for ensuring that the client receives the best execution possible. Best execution does not necessarily mean that clients receive the lowest possible commission costs but that the qualitative execution is best. In other words, all conditions surrounding the transaction execution are in your best interest. When considering best execution, we look at a number of factors besides prices and rates including, but not limited to: • Execution capabilities (e.g., market expertise, ease/reliability/timeliness of execution, responsiveness, integration with existing systems of the advisor, ease of monitoring investments) • Products and services offered (e.g., investment programs, back-office services, technology, regulatory compliance assistance, research and analytic services) • Financial strength, stability and responsibility • Reputation and integrity TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 26 • Ability to maintain confidentiality. We exercise reasonable due diligence to make certain that the best execution is obtained for all clients when implementing any transaction by considering the back-office services, technology and pricing of services offered. Directed Brokerage Clients should understand that not all investment advisors require the use of a particular broker/dealer or custodian. Some investment advisors allow their clients to select whichever broker/dealer the client decides. By requiring clients to use a particular broker/dealer, TVAMP may not achieve the most favorable execution of client transactions and the practice requiring the use of specific broker/dealers may cost clients more money than if the client used a different broker/dealer or custodian. However, for compliance and operational efficiencies, TVAMP has decided to require our clients to use broker/dealers and other qualified custodians determined by TVAMP. The foregoing requirement does not apply to held-away accounts managed through the Pontera platform (see Item 4), which remain custodied with your existing account provider or plan recordkeeper. TVAMP does not select the custodian or recordkeeper for held-away accounts, does not negotiate the commissions, transaction charges, or other fees applicable to those accounts, and is limited to the investment options and trading functionality made available by the provider. In addition, where TVAMP engages a sub-adviser for your account (see Item 4), the account may be maintained at another qualified custodian with which the sub- adviser maintains a relationship (for example, Fidelity), and trades in the account will be executed through that custodian. Broker/Dealer Affiliation TVAMP will generally require that clients establish a brokerage account with LPL Financial or Charles Schwab & Co., Inc. (“Schwab”), (collectively “Custodians”), to maintain custody of clients’ assets and to affect trades for their accounts. The Custodians provide brokerage and custodial services to independent investment advisory firms, including TVAMP. For TVAMP’s accounts custodied at LPL Financial or Schwab, the Custodians generally are compensated by clients through commissions, trails, or other transaction-based fees for trades that are executed through the Custodians or that settle into the Custodians’ accounts. For IRA accounts, the Custodians can charge account maintenance fees. In addition, the Custodians also charge clients miscellaneous fees and charges, such as account transfer fees. The Custodians charge TVAMP an asset-based administration fee for administrative services provided by the Custodians. Such administration fees are not directly borne by clients but may be taken into account when TVAMP negotiates its advisory fee with clients. While the Custodians do not participate in, or influence the formulation of, the investment advice TVAMP provides, certain supervised persons of ADVISOR are Dually Registered Persons. Dually Registered Persons are restricted by certain FINRA rules and policies from maintaining client accounts at another custodian or executing client transactions in such client accounts through any broker-dealer or custodian that is not approved by the Custodians. As a result, the use of other trading platforms must be approved not only by TVAMP, but also by the Custodians. Clients should also be aware that for accounts where LPL Financial or Schwab serves as the custodian, TVAMP is limited to offering services and investment vehicles that are approved by the Custodian and may be prohibited from offering services and investment vehicles that may be available through other broker- dealers and custodians, some of which may be more suitable for a client’s portfolio than the services and investment vehicles offered through LPL Financial or Schwab. TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 27 Clients should understand that not all investment advisers require that clients custody their accounts and trade through specific broker-dealers. Clients should also understand that LPL Financial and Schwab are responsible under FINRA rules for supervising certain business activities of TVAMP and its Dually Registered Persons that are conducted through broker-dealers and custodians other than the Custodians. The Custodians charge a fee for their oversight of activities conducted through these other broker-dealers and custodians. This arrangement presents a conflict of interest because TVAMP has a financial incentive to recommend that you maintain your account with LPL Financial or Schwab rather than with another broker-dealer or custodian to avoid incurring the oversight fee. Benefits Received by TVAMP Personnel The Custodians make available to TVAMP various products and services designed to assist TVAMP in managing and administering client accounts. Many of these products and services may be used to service all or a substantial number of TVAMP’s accounts, including accounts not held with the Custodians. These include software and other technology that provide access to client account data (such as trade confirmation and account statements); facilitate trade execution (and aggregation and allocation of trade orders for multiple client accounts); provide research, pricing information and other market data; facilitate payment of TVAMP’s fees from its clients’ accounts; and assist with back-office functions; recordkeeping and client reporting. The Custodians also make available to TVAMP other services intended to help TVAMP manage and further develop its business. Some of these services assist TVAMP to better monitor and service program accounts maintained at LPL Financial and Schwab, however, many of these services benefit only TVAMP, for example, services that assist TVAMP in growing its business. These support services and/or products may be provided without cost, at a discount, and/or at a negotiated rate, and include practice management-related publications; consulting services; attendance at conferences and seminars, meetings, and other educational and/or social events; marketing support; and other products and services used by TVAMP in furtherance of the operation and development of its investment advisory business. Where such services are provided by a third-party vendor, the Custodians will either make a payment to TVAMP to cover the cost of such services, reimburse TVAMP for the cost associated with the services, or pay the third-party vendor directly on behalf of TVAMP. The products and services described above are provided to TVAMP as part of its overall relationship with LPL Financial and Schwab. While as a fiduciary TVAMP endeavors to act in its clients’ best interests, the receipt of these benefits creates a conflict of interest because TVAMP’s requirement, request or recommendation that clients custody their assets at LPL Financial and Schwab are based in part on the benefit to TVAMP of the availability of the foregoing products and services and not solely on the nature, cost or quality of custody or brokerage services provided by the Custodians. TVAMP’s receipt of some of these benefits may be based on the amount of advisory assets custodied on the Custodians’ platforms. Transition Assistance Benefits LPL Financial provides various benefits and payments to Dually Registered Persons that are new to the TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 28 LPL Financial platform to assist the representative with the costs (including foregone revenues during account transition) associated with transitioning his or her business to the LPL Financial platform (collectively referred to as “Transition Assistance”). The proceeds of such Transition Assistance payments are intended to be used for a variety of purposes, including but not necessarily limited to, providing working capital to assist in funding the Dually Registered Person’s business, satisfying any outstanding debt owed to the Dually Registered Person’s prior firm, offsetting account transfer fees (ACATs) payable to LPL Financial as a result of the Dually Registered Person’s clients transitioning to LPL Financials’ custodial platform, technology set-up fees, marketing and mailing costs, stationary and licensure transfer fees, moving expenses, office space expenses, staffing support and termination fees associated with moving accounts. The amount of the Transition Assistance payments are often significant in relation to the overall revenue earned or compensation received by the Dually Registered Person at his/her prior firm. Such payments are generally based on the size of the Dually Registered Person’s business established at their prior firm and/or assets under custody at LPL Financial. Please refer to the relevant Part 2B brochure supplement for more information about the specific Transition Payments your representative receives. Transition Assistance payments and other benefits are provided to associated persons of TVAMP in their capacity as registered representatives of LPL Financial. However, the receipt of Transition Assistance by such Dually Registered Persons creates conflicts of interest relating to TVAMP’s advisory business because it creates a financial incentive for TVAMP’s representatives to recommend that its clients maintain their accounts with LPL Financial. In certain instances, the receipt of such benefits is dependent on a Dually Registered Person maintaining its clients’ assets with LPL Financial and therefore TVAMP has an incentive to recommend that clients maintain their account with LPL Financial in order to generate such benefits. TVAMP attempts to mitigate these conflicts of interest by evaluating and recommending that clients use LPL Financials’ services based on the benefits that such services provide to our clients, rather than the Transition Assistance earned by any particular Dually Registered Person. TVAMP considers LPL Financials’ quality and costs of services when requiring that clients maintain accounts with LPL Financial. However, clients should be aware of this conflict and take it into consideration in making a decision whether to custody their assets in a brokerage account at LPL Financial. Soft Dollar Benefits An investment adviser receives soft dollar benefits from a broker-dealer when the adviser receives research or other products and services in exchange for client securities transactions or maintaining an account balance with the broker-dealer. TVAMP does not have a soft dollar agreement with a broker-dealer or a third-party. However, TVAMP may receive brokerage and research services from its qualified custodians. These services are within the purview of “soft dollars” benefits pursuant to the “safe harbor” of Section 28(e) of the Securities Exchange Act of 1934, as amended. These services are for the benefit of TVAMP in consideration of the Adviser’s allocation of brokerage transactions made on behalf of Clients (on both an agency and net basis) and may not directly benefit Client accounts. The receipt of soft dollar benefits may influence. TVAMP’s decisions regarding recommending that Clients’ establish accounts at TVAMP’s preferred custodian, based on TVAMP’s interest in receiving brokerage services that benefit TVAMP’s business TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 29 rather than based on the Client’s interest in receiving the best value in custody services and the most favorable execution of Client transactions. This is a potential conflict of interest. TVAMP receives software services and technology for market research and analysis from Schwab. TVAMP believes, however, that its recommendation of Schwab is in the best interests of its clients. TVAMP believes that its clients do not pay more for investment transactions effected and assets maintained at Schwab as a result of these arrangements. TVAMP’s selection is primarily supported by the scope, quality, and price of Schwab’s services (see Item 12 “Selection and Recommendation”) and not Schwab’s services that benefit only TVAMP. TVAMP normally receives ancillary benefits, including: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk serving adviser participants exclusively; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; ability to have investment advisory fees deducted directly from client accounts; access to an electronic communication network for client order entry and account information; receipt of compliance publications; and access to mutual funds which generally require significantly higher minimum initial investments or are generally available only to institutional investors. The foregoing benefits are received solely through participation in Schwab, and do not necessarily depend upon the proportion of transactions directed to Schwab. Handling Trade Errors TVAMP has implemented procedures designed to prevent trade errors; however, trade errors in client accounts cannot always be avoided. Consistent with its fiduciary duty, it is the policy of TVAMP to correct trade errors in a manner that is in the best interest of the client. In cases where the client causes a trade error, the client is responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, the client may not be able to receive any gains generated as a result of the error correction. In all situations where the client does not cause the trade error, the client is made whole and any loss resulting from the trade error is absorbed by TVAMP if the error is caused by the firm. If the error is caused by the broker-dealer, the broker-dealer is responsible for handling the trade error. If an investment gain results from the correcting trade, the gain remains in the client’s account unless the same error involves other client account(s) that should also receive the gains. It is not permissible for all clients to retain the gain. TVAMP may also confer with a client to determine if the client should forego the gain (e.g., due to tax reasons). TVAMP will never benefit or profit from trade errors. Block Trading Policy We may elect to purchase or sell the same securities for several clients at approximately the same time. This process is referred to as aggregating orders, batch trading or block trading and is used by our firm when TVAMP believes such action may prove advantageous to clients. If and when we aggregate client orders, allocating securities among client accounts is done on a fair and equitable basis. Typically, the process of aggregating client orders is done in order to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis in order to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placed independently. TVAMP uses the pro rata allocation method for transaction allocation. TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 30 Under this procedure, pro rata trade allocation means an allocation of the trade at issue among applicable advisory clients in amounts that are proportional to the participating advisory client’s intended investable assets. TVAMP will calculate the pro rata share of each transaction included in a block order and assign the appropriate number of shares of each allocated transaction executed for the client’s account. If and when we determine to aggregate client orders for the purchase or sale of securities, including securities in which TVAMP or our associated persons may invest, we will do so in accordance with the parameters set forth in the SEC No-Action Letter, SMC Capital, Inc. Neither we nor our associated persons receive any additional compensation as a result of block trades. Agency Cross Transactions Our associated persons are prohibited from engaging in agency cross transactions, meaning we cannot act as brokers for both the sale and purchase of a single security between two different clients and cannot receive compensation in the form of an agency cross commission or principal mark-up for the trades. Item 13 – Review of Accounts Account Reviews Notwithstanding the limited scope of certain engagements, TVAMP provides all Clients with continuous access to accounts via secure third party partners that have relevant client information. Clients may view account-related documents such as account statements and performance summaries. On a periodic basis, TVAMP contacts each Client to remind them to review and update personal profile information they previously provided. Asset Managed Accounts TVAMP will monitor discretionary accounts on an ongoing basis. Asset Managed Account reviews are conducted annually with the client, or more often as circumstances warrant. Managed Account reviews consider investment strategy and objectives and result in changes to strategy if necessary. Reviews are conducted by the investment advisor representative assigned to the account with reviews performed in accordance with your investment goals and objectives. Held-away accounts managed through the Pontera platform are monitored through the platform and are reviewed in the same manner as other accounts receiving asset management services. Accounts managed by a sub-adviser are reviewed periodically by TVAMP, including a review of the sub-adviser's performance and continued appropriateness for the client. Nondiscretionary For Clients receiving non-discretionary consulting services pursuant to a limited engagement, TVAMP does not proactively review Client accounts. Rather, portfolio reviews are conducted only upon the express request of the Client. Clients acknowledge and agree that TVAMP provides non-discretionary consulting services solely in response to Client-initiated inquiries and that TVAMP is under no obligation to provide investment or portfolio strategy recommendations unless requested. TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 31 Financial Planning Our financial planning services may terminate upon the presentation of the written plan or may continue depending on the arrangement with the client. Our financial planning and consulting services do not include monitoring the investments of your account(s), and therefore, there’s no ongoing review of your account(s) under such services. Statements and Reports For our asset management services, you are provided with transaction confirmation notices and regular quarterly account statements directly from the qualified custodian. Additionally, TVAMP may provide position or performance reports to you quarterly and upon request. Whether reports by outside money managers are provided to you will depend upon the outside money manager. Financial planning clients will receive reports as agreed between the client and advisor, which may include a comprehensive written plan and progress reports over time. You are encouraged to always compare any reports or statements provided by us, a sub-advisor or third- party money manager against the account statements delivered from the qualified custodian. When you have questions about your account statement, you should contact our firm and the qualified custodian preparing the statement. Item 14 – Client Referrals and Other Compensation TVAMP has entered into agreements with various parties (Referring Parties) to refer clients to TVAMP. If a referred client enters into an investment advisory agreement with TVAMP, a cash referral fee is paid to the referring party, which is based upon a percentage of the client advisory fees that are generated. The referral agreements between any referring party and TVAMP will not result in any charges to clients in addition to the normal level of advisory fees charged. When a client is referred to us by a referring party, the referring party provides the client with a copy of our Disclosure Brochure as required by the Investment Advisers Act of 1940. At or before the time of the referral, the client will also receive a separate promoter disclosure describing the referring party’s relationship with TVAMP and the compensation paid, as required by Rule 206(4)-1 under the Investment Advisers Act of 1940 (the “Marketing Rule”). If the referring party is an unaffiliated registered investment adviser firm, then the client will also receive a copy of the referring party’s Form ADV Part 2 Disclosure Brochure. If a referred client enters into an investment advisory agreement with TVAMP, a referral fee is paid to the referring party. The referral relationship will not result in clients being charged any fees over and above the normal advisory fees charged for the advisory services provided. The referral agreements between TVAMP and referring parties are in compliance with the Marketing Rule and applicable state securities rules governing compensated referral arrangements. Marketing Arrangements with Financial Institutions TVAMP has established and will continue to establish marketing arrangements with banks, credit unions and other financial institutions. In certain circumstances, the investment advisory services of TVAMP may also be marketed through these banks, credit unions and other financial institutions, provided that such TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 32 marketing is done in compliance with applicable SEC and state regulations. Further, TVAMP may have Advisor Representatives conducting business from and/or affiliated with a bank or other financial institution. As a result of these marketing agreements, the financial institution may receive compensation representing payment for the use of the facilities and equipment of the financial institution(s), in the form of program support or rent payment and/or a portion of advisory fees or securities commissions paid to the representatives for sales to customer/members of the financial institution. These relationships may create compliance issues relative to consumer protection. The joint guidelines of regulators of the depository institution call for, at a minimum, both written and verbal disclosure at or prior to the time securities products are purchased or sold that such securities products: • Are not insured by the Federal Deposit Insurance Corporation (FDIC) or National Credit Union Share Insurance Fund, the Federal Deposit Insurance Corp., the National Credit Union Administration, or any other federal or state deposit guarantee fund or other government agency; • Not endorsed or guaranteed by the bank or credit union or their affiliates; • Are not deposits or obligations of the depository institutions and are not guaranteed by the • depository institutions; Investments and securities are subject to investment risks, including possible loss of principal invested. Broker Dealer Additional Compensation TVAMP and/or its Dually Registered Persons are incented to join and remain affiliated with LPL Financial and to recommend that clients establish accounts with LPL Financial through the provision of Transition Assistance (discussed in Item 12 above). LPL also provides other compensation to TVAMP and its Dually Registered Persons, including but not limited to, bonus payments, repayable and forgivable loans, stock awards and other benefits. The receipt of any such compensation creates a financial incentive for your representative to recommend LPL Financial as custodian for the assets in your advisory account. We encourage you to discuss any such conflicts of interest with your representative before making a decision to custody your assets at LPL Financial. Promoter Arrangement with an Online Referral Platform TVAMP has entered into a written referral agreement with an unaffiliated SEC-registered investment adviser that operates an online referral platform (the “Promoter”). The Promoter refers prospective clients to TVAMP through its online platform. If you are referred by the Promoter and engage TVAMP for advisory services, TVAMP pays the Promoter a referral fee based on a percentage of the advisory fees TVAMP receives from you. For asset-based advisory relationships, this compensation continues for the duration of the advisory relationship. For fixed-fee or hourly engagements, the referral compensation is paid for a limited period as specified in the referral agreement. The referral fee is paid solely by TVAMP and does not result in any additional charge to you or increase the advisory fee you pay. The Promoter is not authorized to provide investment advice on behalf of TVAMP or to bind TVAMP in any manner. An advisory relationship is established only upon execution of a written agreement between you and TVAMP. This arrangement creates a conflict of interest because TVAMP shares advisory revenue with the Promoter for referred clients. The Promoter also has an incentive to recommend TVAMP because it TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 33 receives compensation from TVAMP. Clients are under no obligation to engage TVAMP for advisory services. The Promoter also serves as a sub-adviser for certain TVAMP client accounts, as described in Items 4, 5 and 10 of this Brochure. Additional Compensation TVAMP’s primary compensation for advisory services consists of the fees described in Item 5 of this Disclosure Brochure. As described in Item 14, TVAMP may compensate third parties for client referrals. TVAMP does not receive additional third-party compensation in connection with providing investment advice, except as disclosed in this Brochure. Please refer to Item 5 (Fees and Compensation), Item 10 (Other Financial Industry Activities and Affiliations), Item 12 (Brokerage Practices), and Item 14 (Client Referrals and Other Compensation) for additional information regarding compensation and related conflicts of interest. From time to time, TVAMP or its representatives may receive expense reimbursements for travel and/or marketing expenses from distributors or sponsors of investment or insurance products. Travel reimbursements are typically associated with attendance at due diligence or investment training events hosted by product sponsors. Marketing reimbursements may include support for costs related to client events, seminars, advertising, or educational materials. Although these reimbursements are not conditioned upon the achievement of specific sales quotas, they are generally provided by sponsors whose products are used or may be used by clients. This creates a conflict of interest because it presents an incentive to recommend certain products or services. TVAMP addresses this conflict by basing all investment recommendations on the individual needs, objectives, and best interests of its clients. Item 15 – Custody Custody, as it applies to investment advisors, has been defined by regulators as having access to or control over client funds and/or securities. In other words, custody is not limited to physically holding client funds and securities. If an investment advisor has the ability to access or control client funds or securities, the investment advisor is deemed to have custody and must ensure proper procedures are implemented. TVAMP does not maintain physical possession of client cash or securities; however, pursuant to Rule 206(4)-2 of the Advisers Act, TVAMP is deemed to have limited custody of client funds because we have the authority and ability to debit our fees directly from certain clients’ accounts. TVAMP is also deemed to have custody when a client establishes certain types of letters of instruction or other asset transfer authorization arrangement with their qualified custodian, authorizing TVAMP to disburse funds to one or more third parties specifically designated by the client. TVAMP relies on SEC guidance for firms with this type of custody, and is not subject to a surprise annual audit as TVAMP confirms it meets the requirements of the 7- step test as established by the SEC, to avoid being subject to a surprise annual audit. For accounts in which TVAMP is deemed to have custody, we have established procedures to ensure all client funds and securities are held by a qualified custodian in a separate account for each client under that client’s name. Clients or an independent representative of the client will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 34 manner in which the funds or securities are maintained. Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. Clients should carefully review those statements and are urged to compare the statements against reports received from TVAMP. When clients have questions about their account statements, they should contact TVAMP or the qualified custodian preparing the statement. When fees are deducted from an account, the custodians are responsible for calculating and deducting the fee and remitting a portion of the fee to TVAMP. Your account statement will contain an itemization of the formula used to calculate the fee, the amount of assets under management the fee is based on, and the time period covered by the fee. Held-Away Accounts TVAMP manages held-away accounts through the Pontera order management platform in a manner designed to avoid custody of client funds and securities. You establish and maintain the connection to your held-away account(s) directly through the Pontera platform and retain exclusive possession and control of your account login credentials. TVAMP does not accept, hold, or have access to usernames, passwords, or other login credentials for held-away accounts, and you should never share those credentials with TVAMP or your investment adviser representative. TVAMP's access through the platform is limited to viewing account information and submitting transactions among the investment options available within the account; TVAMP cannot withdraw or transfer funds or securities from a held-away account, change the account owner's information, or otherwise access your assets. Where you authorize fees for a held-away account to be deducted from another account maintained at a qualified custodian, that authorization is part of the limited custody arising from fee deduction described above. Item 16 – Investment Discretion When providing asset management services, TVAMP maintains trading authorization over your Account and can provide management services on a discretionary basis. When discretionary authority is granted, we will have the authority to determine the type of securities, the amount of securities that can be bought or sold, the broker or dealer to be used, and the commission rates paid for your portfolio without obtaining your consent for each transaction. If you decide to grant trading authorization on a non-discretionary basis, we will be required to contact you prior to implementing changes in your account. Therefore, you will be contacted and required to accept or reject our investment recommendations including: • The security being recommended. • The number of shares or units • Whether to buy or sell Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing of buying or selling an investment and the price at which the investment is bought or sold. If your accounts are managed on a non-discretionary basis, you need to know that if you are not able to be reached or are slow to respond to our request, it can have an adverse impact on the timing of trade implementations and we may not achieve the optimal trading price. You will have the ability to place reasonable restrictions on the types of investments that may be purchased in your Account. You may also place reasonable limitations on the discretionary power granted to TVAMP so long as the limitations are specifically set forth or included as an attachment to the client agreement. For sub-account management services, upon receiving written authorization, TVAMP will maintain trading authorization over your accounts. Upon receiving written authorization from you, we may implement TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 35 trades on a non-discretionary basis. This means we will be required to contact you prior to implementing changes to your account. However, we will be responsible for making decisions regarding the timing of buying or selling an investment and the price at which the investment is bought or sold. For held-away accounts managed through the Pontera platform, TVAMP exercises the trading authorization granted in your client agreement on a discretionary basis, limited to selecting among the investment options available within the account (for example, the plan's investment lineup) and directing rebalancing and reallocation transactions through the platform. TVAMP's authority over held-away accounts does not include the ability to withdraw or transfer assets, make contributions or distributions, or change account features. When TVAMP engages a sub-adviser for your account, TVAMP may delegate to the sub-adviser the trading authority granted by you in order to implement transactions in the account in accordance with the selected model or strategy. TVAMP retains the authority to select, monitor, replace, and terminate the sub-adviser and to change the model or strategy used for your account. Item 17 – Voting Client Securities TVAMP does not vote proxies on behalf of Clients. We have determined that taking on the responsibility for voting client securities does not add enough value to the services provided to you to justify the additional compliance and regulatory costs associated with voting client securities. Therefore, it is your responsibility to vote on all proxies for securities held in Account. You will receive proxies directly from the qualified custodian or transfer agent; we will not provide you with the proxies. You are encouraged to read through the information provided with the proxy-voting documents and make a determination based on the information provided. Although we do not vote client proxies, if you have a question about a particular proxy feel free to contact us. However, you will have the ultimate responsibility for making all proxy-voting decisions. With respect to assets managed by an outside money manager, we will not vote the proxies associated with these assets. You will need to refer to each outside money manager’s disclosure brochure to determine whether the outside money manager will vote proxies on your behalf. You may request a complete copy of a third-party money manager’s proxy voting policies and procedures as well as information on how your proxies were voted by contacting TVAMP at the address or phone number indicated on Page 1 of this disclosure document. Item 18 – Financial Information This item is not applicable to this brochure. TVAMP does not require or solicit prepayment of more than $1200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet for the most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. Finally, TVAMP has not been the subject of a bankruptcy petition at any time. Class Action Lawsuits You retain the right under applicable securities laws to initiate individually a lawsuit or join a class-action lawsuit against the issuer of a security that was held, purchased, or sold by or for client. TVAMP does not TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 36 initiate such legal proceedings on behalf of clients and does not provide legal advice to clients regarding potential causes of action against such a security issuer and whether the client should join a class-action lawsuit. We recommend that you seek legal counsel prior to making a decision regarding whether to participate in such a class-action lawsuit. Upon your specific instruction, we may provide assistance to you regarding an investment history related to the security underlying the individual, or class-action, lawsuit and may provide assistance with the completion of this portion of certain class-action paperwork. At no time should such assistance be deemed as a substitute for consulting with legal counsel. TVAMP Customer Privacy Policy Notice The information contained in this section will also be disclosed in TVAMP’s Privacy Policy Statement. This statement will be provided to all clients in accordance with the rules and regulations of the Gramm Leach-Bliley Act of 1999. As a financial services firm, TVAMP, LLC will gather and use nonpublic personal information (NPI) in order to provide our clients (prospective, current, or former) with a broad range of financial services. We are providing this notification to inform you of the types of NPI we collect, our privacy safeguards, and sharing practices. We handle all NPI in accordance with this policy. Nonpublic personal information (NPI) is confidential personal information about you that we obtain in connection with providing financial services or products to you. Generally, NPI about you is collected from the following sources: • • • Information contained within applications or other forms; Information about your transactions with us, our affiliates, our service providers, or other parties to transactions; and Information we may receive about you from unaffiliated financial service providers (e.g. custodians, insurance agents, attorneys, and consumer reporting agencies) We do not disclose any NPI about you without your express consent, except as described in this notice. We only share your NPI with: 1. Employees of our firm; 2. Affiliates of our firm, including TVAMP Tax Planning, LLC ; 3. Unaffiliated service providers (e.g. broker-dealers, banks, subadvisors, co-advisors, third-party managers, platform providers, account aggregation services and mutual fund companies) as necessary to effect, administer, or enforce transactions that the client has requested or authorized; 4. Professional advisors, including information technology consultants, compliance consultants, legal counsel, accounting firms, cybersecurity providers, and other vendors, solely to the extent necessary for them to perform services on the Firm’s behalf and to support the Firm’s fiduciary and operational responsibilities to clients 5. Other who need to know such information in order to provide products or services to you; and 6. Any other person or entity with whom we are permitted or required by law to share it. TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 37 Disclosure of NPI is limited to what is necessary to provide advisory services to clients, administer client accounts, fulfill legal and regulatory obligations, or otherwise conduct the Firm’s business in accordance with applicable law. SMS Terms and Conditions We may ask you for consent to send you “Short Message Service” messages. SMS is used to provide clients with messages, scheduling and meeting reminders. SMS mobile opt-in consent is not shared with third parties nor is your SMS data shared with third parties. Messaging frequency may vary. Message and data rates may apply. To opt out at any time, text STOP. For assistance, text HELP or visit our website at https://www.tvamp.net. Visit https://www.tvamp.net/privacy-policy/ for privacy policy and Terms of Service. We maintain physical, electronic, and procedural safeguards to protect your NPI, Our safeguards include measures to protect your information prior to, during and upon termination of our financial services engagement (i.e. disposal of your data). The Firm also conducts due diligence and ongoing oversight of service providers with access to NPI and requires such providers to implement reasonable administrative, technical, and physical safeguards designed to protect client information and notify the Firm of any material security incidents affecting such information. We do not sell, share, or disclose your personal information to persons or entities other than as described above. We will not share or disclose such information to non-affiliated third-party marketing companies. When a client or prospective client account is closed, TVAMP, LLC will continue to keep all client information confidential in accordance with the principles stated in its privacy policy. A copy of the Privacy Policy Notice will be delivered to all clients and prospective clients in writing by at least one of the following methods: • • • • By hand delivering a copy to the client or prospective client • Mailing a copy to the client’s or prospective client’s address on record • If business is conducted electronically, a notice may be posted on an electronic site as long as the client or prospective client acknowledges receipt of the Privacy Policy Notice prior to the client obtaining any services or products from TVAMP, LLC Any time a change is made to the Privacy Policy, the statement to clients or prospective clients will be revised. The revised statement will be given to all affected clients prior to any disclosure of information. In addition, TVAMP, LLC will provide a copy of its Privacy Policy Statement to all current and existing clients or prospective clients as required by law. If you have any questions regarding our privacy policy, please do not hesitate to contact your investment adviser representative or you may write to, email, or call us at: connect@tvamp.com 865-226-9982 TVAMP, LLC 6025 Brookvale Lane Suite 160 Knoxville, TN 37919 TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 38 Office Locations 6154 Popes Creek Place Haymarket, VA 703-754-2839 11566 Chapman Highway Seymour, TN 37865 (865) 577-1922 4273 Olde Mill Ln NE Atlanta, GA 30342 306 Main Street Jacksboro, TN 37757 (423) 566-4000 1113 Hunter’s Crossing Alcoa, TN 37701 (865) 226-9982 1339 Volunteer Parkway Bristol, TN 37620 (865)544-5400 (865) 544-5400 662 E. Broadway Blvd 2004 N. Roan Street Jefferson City, TN 37760 Johnson City, TN 37601 (865) 544-5400 (865) 544-5400 4611 Kingston Pike 2518 E. Stone Drive Kingsport, TN 37660 Knoxville, TN 37919 (865) 544-5400 (865) 544-5400 31 Market Square 7459 Maynardville Pike Knoxville, TN 37902 Knoxville, TN 37938 (865) 544-5400 (865) 544-5400 4118 Asheville Hwy 1974 Town Center Blvd Knoxville, TN 37922 Knoxville, TN 37914 (865) 544-5400 (865) 544-5400 1316 Wilson Rd 4520 Greenway Drive Knoxville, TN 37912 Knoxville, TN 37918 (865)544-5400 (865)544-5400 455 Market Drive 2325 Market Place Drive Lenoir City, TN 37771 Maryville, TN 37801 (865) 544-5400 (865)544-5400 3101 Millers Point Drive 5327 Winner’s Circle Rd Morristown, TN 37813 Morristown, TN 37813 (865)544-5400 (865)544-5400 4310 Winkler Ave 1916 Roane State Highway Morristown, TN 37814 Harriman, TN 37748 (865)544-5400 (865)544-5400 1037 Middlecreek Rd 7210 Chapman Hwy Sevierville, TN 37862 Knoxville, TN 37920 (865)544-5400 (865)544-5400 TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 39 ADDITIONAL LOCATIONS – continued 5271 Highway 11E Piney Flatts, TN 37686 (865) 544-5400 7515 Central Avenue Pike Powell, TN 37849 (865) 544-5400 11490 Parkside Drive 102 N Seven Oaks Drive Farragut, TN 37934 Knoxville, TN 37922 (865)544-5400 (865)544-5400 711 W 1st North St. Morristown, TN 37814 (423) 616-0182 TVAMP, LLC Form ADV Part 2A Disclosure Brochure Page 40