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Trust Investment Advisors
Form ADV Parts 2A and 2B
Item 1
301 Pennsylvania Parkway
Suite 301
Indianapolis, IN 46280
(317) 253-2000
www.tiadvisors.com
August 2025
This brochure provides information about the qualifications and business practices of TRUST
INVESTMENT ADVISORS. If you have any questions about this brochure, please contact our
compliance consultant, Sue Mitchell at smitchell@tiadvisors.com. The information in this brochure
has not been approved or verified by the Securities and Exchange Commission (SEC), the state of
Indiana or any other state securities authority.
information
about our
firm
available on
the SEC’s website
Additional
at
is
www.adviserinfo.sec.gov. Our firm is a Registered Investment Advisor. We are required to
inform you that registration itself does not imply a certain level of skill or training.
Item 2 – Material Changes
This Brochure will be updated and resubmitted to the regulatory agencies anytime material changes
occur. Prospective clients of our advisory services will receive a copy of this Form ADV Parts 2A,
2B, Form CRS and its Privacy Notice. Material changes will be communicated annually to each of
our clients.
Trust Investment Advisors moved to a new location: 301 Pennsylvania Parkway, Suite 301,
Indianapolis, IN 46280. All contact information, including phone numbers have remained the same.
TIA’s Privacy Policy
We do not sell consumer information to anyone. Confidential and non-public information is
collected to provide financial advice and services, to complete transactions or to make clients aware
of other services available through us. Clients will receive a copy of our Privacy Notice at the
inception of the new advisory relationship and on an annual basis thereafter. A copy is available
upon request at no charge by contacting Sue Mitchell at smitchell@tiadvisors.com.
TIA Form ADV Parts 2A & 2B
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Table of Contents
1
2
Item 1 – Cover Page
Item 2 - Material Changes and Privacy Notice
Item 2 – Material Changes
Item 4 – Advisory Business
Item 3 – Table of Contents
3
4
Item 4 – Advisory Business
Item 5 - Fees and Compensation
Item 5 – Fees and Compensation
14
Item 6 - Performance-Based Fees and Side-by-Side Management
16
Item 7 - Types of Clients
16
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
16
Item 9 – Disciplinary Information
19
Item 10 - Other Financial Industry Activities and Affiliations
19
Item 11 - Code of Ethics, Participation, or Interest in Client Transactions
19
and Personal Trading
Item 12 – Custodian/Brokerage Practices
21
Item 13 - Review of Accounts
22
Item 14 - Client Referrals and Other Compensation
23
Item 15 - Custody
23
Item 16 - Investment Discretion
23
Item 17 - Voting Client Securities
24
Item 18 - Financial Information
24
Item 19 - Requirements for State-Registered Advisors
24
2
Attachment: Form ADV 2B – Supplements
25
A
Am ADV Part 2B - Supplement
TIA Form ADV Parts 2A & 2B
SEM Originated 4-20 rev 8/2025
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TIA Form
ADV Parts
2A & 2B
Item 4 – Advisory Business
Trust Investment Advisors, doing-business-as TIA, is an SEC-registered investment advisory firm
owned by Burton P. Street (“Street”) as of June 2020.
For additional information pertaining to Street’s business experience and credentials, please refer to
Form ADV Part 2B (“the Supplement”), which is included with this Form ADV Part 2A
(“Brochure”).
As a registered investment advisor we provide comprehensive investment advice and for existing
investment clients, we provide consulting and personalized financial services such as retirement
planning, charitable giving strategies, insurance analysis, estate planning and other related strategies
for accumulating and preserving wealth. These services are provided to individuals/families,
business owners, charitable organizations, private foundations, and other professional advisors
(collectively “client”).
All clients will receive investment advisory services, and financial planning will be offered to our
existing clients on a requested basis.
As of December 31, 2024, TIA had total assets under management in excess of $200 million.
Investment Advisory Services:
Overview
We provide continuous asset management to clients based on the individual needs of the client
primarily using model portfolios of stocks and fixed income securities. We create and manage an
investment strategy based on the individual client’s stated goals and objectives. During our data-
gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and
liquidity needs. As appropriate, we may also review and discuss a client’s prior investment history,
as well as family composition and background. Our investment strategy determines an appropriate
asset allocation for the client and utilizes our model equity and fixed income portfolios.
We manage these advisory accounts on a discretionary basis. Account supervision is guided by the
client’s stated objectives (i.e., maximum capital appreciation, growth, income, or growth and
income). Clients may impose reasonable restrictions on investing in certain securities, types of
securities, or industry sectors.
Although not the most important factor for investment decisions, we manage portfolios with
thoughtful attention to the tax implication of transactions. We strive to be tax responsible, tax aware
and tax efficient. However, we are not accountants and therefore, recommend coordination of tax
strategy with your tax advisor.
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Although they may not be part of our model investment strategy, and we can generally include advice
regarding the following securities:
1. Exchange-listed securities.
2. Securities traded over the counter.
3. Warrants.
4. Preferred stock.
5. Corporate debt securities (bonds).
6. Commercial paper.
7. Certificates of deposit.
8. United States governmental securities.
9. Options contracts on securities.
10. Exchange Traded Funds (ETFs).
11. Mutual Funds.
Because some types of investments involve certain additional degrees of risk, they will only be
implemented when consistent with the client's stated investment objectives, tolerance for risk,
liquidity, and suitability.
To ensure the client’s account continues to be managed in a manner consistent with their financial
circumstances, we provide the following services:
1. Statements from their custodian at least quarterly.
2. Quarterly reports to clients who meet certain thresholds for account management.
3. Regular contact with clients to determine changes in their financial situations. Life events
such as marriage, divorce, births, and deaths may prompt the need to meet more
frequently or to meet as soon as possible. We rely on the client to provide updated
information on personal situations that may have an impact on investment planning.
4. Reasonable availability to consult with clients in-person or through phone consultations.
As a fiduciary, we have a duty of utmost good faith to act solely in the best interests of our
investment advisory clients and to make full and fair disclosure of material facts, particularly when
our interests may conflict with the client’s.
Model Portfolio Management
Our investment committee meets on a regular basis to manage the model portfolios. Each model
portfolio is designed to meet a particular investment goal and is incorporated in an overall investment
strategy for each client. There is no guarantee the model portfolios can, or will, achieve their stated
goals and objectives, and past performance is not indicative of future results.
TIA Form ADV Parts 2A & 2B
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The following is a description of the model portfolios as managed by TIA:
Value Equity Portfolio (VEP)
The investment objective of our Value Equity Portfolio (VEP) is to purchase stocks of companies
selling below their intrinsic business value. Our analysts provide independent research, utilizing a
financial database and a proprietary evaluation process.
Our stock selection process has two components: a screening process to determine stocks meeting
our guidelines for inclusion in the VEP, and a valuation process that measures the relative
attractiveness of the stocks passing through the screening process. The valuation process incorporates
the net book value of the assets of the company with its future earnings stream, adjusted for the
estimated long-term growth rate of company earnings.
The screening process we strive for within VEP is to use four guidelines for inclusion:
1. Return on capital greater than the market (as measured by the weighted average of the
S&P 500 index).
2. A debt/total capital ratio of less than 50%.
3. Market capitalization of greater than $1.0 billion.
4. Dividend yield of at least 1%.
The guiding philosophy for these guidelines is to select companies that are financially strong with
better than average returns on capital. In addition, we believe companies in our portfolio should pay
at least a minimal level of dividends with a goal of having a dividend yield exceeding that of the
market. Companies that are/or become exceptions to the guidelines must be reviewed and approved
by the committee.
The investment committee focuses on a fundamental analysis of the undervalued companies coming
through the screening and valuation process. The investment committee reviews individual company
candidates for our portfolios. In-depth analysis of company research, industry reports and current
valuation are performed for each acquisition. In addition to fundamental data, key factors considered
are management, product leadership and industry dynamics.
Stocks are sold from the portfolio for three reasons: 1) the company has performed as expected and
the stock price has reached its full valuation as indicated by our pricing model; 2) unexpected events
change the prospects of the company causing it to fall short of its potential; 3) the investment
committee finds another stock it believes has better prospects.
Typically, VEP will consist of a well-diversified portfolio of 20-30 stocks. We maintain and monitor
diversification guidelines on both a company and industry basis. We have a policy of staying fully
invested at all times and do not try to “time” the market.
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Income Equity Portfolio (IEP)
The investment objective of our Income Equity Portfolio (IEP) is to invest in companies having a
high current yield with a growing stream of dividend income. We perform our own fundamental
research, utilizing a leading financial database to screen for potential purchase candidates meeting
predetermined criteria.
Our stock selection process has two components: a screening process to determine stocks meeting
our guidelines for inclusion in the IEP, and a ranking process based on the company’s dividend yield
and projected dividend yield given its dividend growth rate.
We strive to use the following criteria to screen for stocks for the IEP:
Market capitalization > $1.0 billion.
Dividends/cash flow < 67.0%.
Current yield > Yield on S&P 500 index.
Five-year dividend growth rate > 3.0%.
Stocks selected from the screening process are ranked according to their current and projected
dividend yield. Our analysts strive to use the screening process to pick companies to review for
possible purchase. The analysts perform a fundamental evaluation of the company’s financial
statements, management, and industry to determine its prospects.
Stocks are monitored on an ongoing basis for dividend growth, dividend yield and cash flow.
Companies falling below certain criteria for each ratio are considered exceptions and must be sold
out of the portfolio unless conditions are temporary or would otherwise merit retention of the stock.
Typically, the IEP will consist of a well-diversified portfolio of 20-30 stocks. We may use “common
stock substitutes” such as preferred stock or convertible debt in certain situations, though this is not
a common practice. We maintain and monitor diversification guidelines on both a company and
industry basis. We have a policy of staying fully invested at all times and do not try to “time” the
market.
Growth Equity Portfolio (GEP)
Our Growth Equity Portfolio (GEP) is invested in companies having revenues and earnings growing
faster than the market. The investment objective is to maximize total return by investing in companies
whose products have a marked edge over competitors and whose expected revenue increase will
result in meaningfully stronger earnings prospects. Long-term, superior earnings performance should
lead to significant capital appreciation for the portfolio.
Our stock selection process has two components: a screening process to determine stocks meeting
TIA’s guidelines for inclusion in the GEP and a ranking process based on the company’s price to
TIA Form ADV Parts 2A & 2B
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earnings ratio adjusted for the companies’ long-term earnings growth rate. We use a leading financial
database for stock selection.
We strive to screen the database for growth stocks using the following criteria:
Market Capitalization > 1.0 billion.
Five-year sales compound growth rate > 7.5%.
Five-year average return on equity > 7.5%.
Debt/total capital < 50%.
We use a valuation model based on earnings estimates and projected earnings growth to evaluate
stocks selected through the screening process. The price to earnings ratio utilizing estimates for the
current fiscal year is adjusted for the projected growth rate in earnings. This adjusted ratio is
compared to the ratio for the S&P 500 Index in projecting a fair valuation for the company. We rank
the companies based on their relative attractiveness.
Our analysts use the valuation process to select companies to review for possible purchase. The
investment committee reviews individual company candidates for our portfolios. In-depth analysis
of company research, industry reports and current valuation is performed for each possible
acquisition. In addition to fundamental data, key factors considered are management, product
leadership, and industry dynamics. If the stock is approved by the committee, it is added to the
portfolio.
Stocks are sold from the portfolio for three reasons:
1. The company has performed as expected and the stock price has reached its full valuation
as indicated by our pricing model.
2. Unexpected events change the prospects of the company causing it to fall short of its
potential.
3. The Investment Committee finds another stock it believes has better prospects.
Typically, the GEP will consist of a well-diversified portfolio of 20–35 stocks. We maintain and
monitors diversification guidelines on both a company and industry basis. We have a policy of
staying fully invested at all times and do not try to “time” the market.
Tactical Growth Portfolio (TGP)
Our Tactical Growth Portfolio (TGP) is invested in companies having revenues and earnings growing
faster than the market. The investment objective is to maximize total return by investing in companies
whose products have a marked edge over competitors and whose expected revenue increase will
result in meaningfully stronger earnings prospects. Long-term, superior earnings performance should
lead to significant capital appreciation for the portfolio.
TIA Form ADV Parts 2A & 2B
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Our stock selection process generally has two components: a screening process to determine stocks
meeting TIA’s guidelines for inclusion in the TGP and a ranking process based on technical (opposed
to fundamental) analysis of each individual stock and the overall stock market sentiment. We use a
leading financial database for stock selection.
We screen the database for growth stocks using the following criteria:
Market Capitalization > $.3 Billion.
Market must have over 2 years of price history.
Stock price must be > $7.
Sufficient market liquidity.
We use a technical model based on long, medium- and short- term support and resistance price levels
to evaluate stocks selected through the screening process. Our internal technical models must meet
criteria based on internal market strength of each individual proposed stock. These internal technical
models are used to rank the companies based on their relative attractiveness.
Our analysts use the technical model process to select companies to review for possible purchase.
The investment committee reviews individual company candidates for our portfolios. In-depth
analysis of company research, industry reports and current valuation is performed for each possible
acquisition. In addition to fundamental data, key technical factors considered are overall market
strength, individual market strength, and market sector correlations. If the stock is approved by the
committee, it is added to the portfolio.
Stocks are sold from the portfolio for three reasons:
1. The company has performed as expected and the stock price has reached its full valuation
as indicated by our technical model.
2. Unexpected events change the prospects of the company causing the individual stock
price to technically fail.
3. The Investment Committee finds another stock it believes has better prospects based on
our overall review, which includes the technical modeling process.
Typically, the TGP will consist of a well-diversified portfolio of 20–35 stocks. We maintain and
monitor diversification guidelines on both a company and industry basis. We have a policy of
investing at levels determined by our technical modeling process and therefore we can go to 100%
cash if no opportunities are present.
Tactical Value Portfolio (TVP)
The investment objective of our Tactical Value Portfolio (TVP) is to purchase stocks of companies
selling below their intrinsic business value. Our analysts provide independent research, utilizing a
financial database and a proprietary evaluation process.
TIA Form ADV Parts 2A & 2B
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Our stock selection process generally has two components: a screening process to determine stocks
meeting our guidelines for inclusion in the TVP and a valuation process that measures the relative
attractiveness of the stocks passing through the screening process. The valuation process incorporates
a ranking process based on technical analysis (opposed to fundamental analysis) of each individual
stock and the overall stock market sentiment.
The screening process we strive for within TVP uses four guidelines for inclusion:
1. Market Capitalization > $.3 Billion.
2. Market must have over 2 years of price history.
3. Individual Stock price must be > $7.
4. Sufficient market liquidity.
We use a technical model based on long, medium- and short-term support and resistance price levels
to evaluate stocks selected through the screening process. Our internal technical models must meet
criteria based on internal market strength of each individual proposed stock. These internal technical
models are used to rank the companies based on their relative attractiveness.
The guiding philosophy for these guidelines is to select companies that are financially strong with
better than average returns on capital. In addition, we believe companies in our portfolio should
attempt to pay at least a minimal level of dividends with a goal of having a dividend yield exceeding
that of the market. Companies that perform outside the guidelines must be reviewed and approved
by the investment committee.
The investment committee focuses on fundamental and technical analysis of the undervalued
companies coming through the screening and technical analysis process. The investment committee
reviews individual company candidates for our portfolios. In-depth analysis of company research,
industry reports and current technical analysis is performed for each possible acquisition. In addition
to fundamental data, key technical factors considered are overall market strength, individual market
strength, market sector correlations and individual stock beta. If the stock is approved by the
investment committee, it is added to the portfolio.
Stocks are sold from the portfolio for three reasons: 1) the company has performed as expected and
the stock price has reached its full valuation as indicated by our pricing model or our technical model;
2) unexpected events change the prospects of the company causing it to fall short of its potential and
technically fail; 3) the investment committee finds another stock it believes has better prospects based
on our overall view including the technical outlook.
Typically, TVP will consist of a well-diversified portfolio of 20-30 stocks. We maintain and monitor
diversification guidelines on both a company and industry basis. We have a policy of staying invested
at a level determined by the technical outlook for each individual stock, therefore we can go to 100%
cash if no stock is deemed acceptable from a technical outlook.
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Use of Options Strategies
Any and all options strategies require additional client agreements and are only implemented on
selected, approved client accounts.
1. Covered Call Option Strategy
We use “covered call” option contracts written (sold) to correspond with existing securities currently
held in the portfolio. In this strategy, clients receive a premium (income received from writing/selling
covered call contracts) for agreeing to sell an underlying security at a specific price (“strike price”)
by a specific date (“expiration date”).
We use this strategy as an additional source of income yield to our portfolios.
A risk of covered calls is that the current market price of the underlying security may exceed the
“strike” price of the option contract preventing the sale at a higher price.
Another risk of covered calls exists when option contracts are not exercised, and it is desirable to sell
the underlying security. In this case, the security can either be sold after the expiration date where
the market price may be lower, or the option contract(s) can be bought back resulting in a possible
loss of net income.
The Covered Call Strategy can be utilized for any of the equity-based model portfolios and is selected
for the sophisticated investor seeking the potential to enhance returns. Options carry a higher degree
of risk which should be considered prior to implementation of the strategy. Option strategy investors
must sign an Options Agreement with their custodian.
2. Put Option Strategy - Hedging
A Put or Put Option Strategy is a stock market instrument which gives the holder the right to sell an
asset within their portfolio, at a specified price, by a specified date to the writer of the Put. The
purchase of a Put Option is interpreted as a negative sentiment about the future value of the
underlying stock.
We can use this strategy when a client is concerned the stock market will fall and negatively impact
specific positions in their portfolio.
The Put Option owner’s risk of loss is limited to the premium paid for the Option.
The Put Option Strategy can be utilized for any of the equity-based model portfolios and is selected
for the sophisticated investor seeking the potential to enhance returns. Options carry a higher degree
of risk which should be considered prior to implementation of the strategy. Option strategy investors
must sign an Options Agreement with their custodian.
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3. Put/Call Option Strategy – Yield Enhancing by Writing or Shorting Options
A Put or Call Writing/Selling Option Strategy designed for yield enhancement is a strategy in which
the writer or seller of the Put or Call earns a premium, at a specified price, by a specified date from
the owner of the Put or Call. The sale of a Put or Call Option is interpreted as a short-term bias about
the future value of the underlying stock.
We can use this strategy when a client wants to capture defined short-term volatility of the stock
market, which is perceived to be contained or subdued over a defined period.
The Put/Call Option seller or writer’s risk of loss is unlimited, constrained only by the price of the
underlying stock.
The Put/Call Option Strategy can be utilized for any of the equity-based model portfolios and is
selected for the sophisticated investor seeking the potential to enhance returns. Options carry a
higher degree of risk which should be considered prior to implementation of the strategy. Option
strategy investors must sign an Options Agreement with their custodian.
b
Strategic Income Portfolio Program (SIPP)
We currently have three Strategic Income Portfolio Programs (SIPP):
1. Preferred Income Portfolio Programs (PIP) consisting of $25 par, callable,
exchange-listed securities. This portfolio yield is compared to the 5-year US
Treasury Bond.
2. Non-Cumulative Portfolio Program (NCP) which is a subset of SIPP. This portfolio
is tax-advantaged (dividends qualify for the 20% maximum dividend rate) and is
compared to municipal bond yields.
3. Shorter Call Protection (SCP), also a subset of PIP with less than 2 years call
protection and is compared to the 2-year US Treasury Notes and 2-year Bank CD’s.
The investment objective of our Strategic Income Portfolio Program (SIPP) is two-fold: 1) to provide
a taxable fixed income alternative through fixed dividends and 2) to produce total returns through
the historical yield spreads to US Government Bonds existing in the preferred stock market.
There are several components in our preferred stock philosophy:
1. High quality marketable preferred stocks.
2. Historical yield spread to US Government Bonds.
3. $25 par value.
4. Contractual dividend payments.
5. Perpetual duration range.
6. Less than 5 years average portfolio call protection.
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The following guidelines are generally utilized for individual stock selection:
1. Minimum return of 2% yield spread over respective Treasuries.
2. Individual issues cannot represent more than 8% of the portfolio.
Preferred Stocks selected from the screening process for consideration for purchase must be
approved by the investment committee, adhere to our preferred stock guidelines, or be approved as
an exception by the investment committee.
Stocks are sold based upon failure to meet minimum income returns and/or demonstrate deteriorating
issue fundamentals.
The typical preferred stock portfolio will consist of a diversified portfolio of 20-30 stocks selected
from an Investment Committee approved list. We maintain and monitor diversification guidelines on
both a company and industry basis. We have a policy of staying fully invested at all times and do not
try to “time” the market.
Elements of Financial Planning:
Financial planning will be offered to our investment advisory clients at no additional charge. Not all
clients will choose to engage in the full scope of services offered. The specifics of services rendered
will be personalized based on the needs and request of each individual investment advisory client.
Clients may receive varying levels of this service and not all may choose to utilize them.
Retirement Planning - with fewer companies offering full pension plans and the uncertainty of Social
Security, it has become more important than ever to save and plan for one’s own retirement.
Unfortunately, many people feel they simply do not have enough money left over each month to
save. Retirement savings needs to become a priority instead of an afterthought. Through a
disciplined approach, we help our clients establish savings plans that are realistic and affordable.
Estate Planning - one of the most overlooked and difficult elements of a financial plan is estate
planning. Estate planning can, and should, be used to eliminate uncertainty over the administration
of one’s assets and maximize the benefits to designated heirs. We can help our clients plan for the
unknown and will work with and/or recommend attorneys. Implementing a responsible estate plan
may include reviewing one’s current Will and other estate-planning documents and possibly
recommending trusts as well as addressing philanthropic intent.
Insurance Analysis – we help our clients sort through the many types and purposes of insurance.
Insurance coverage is important to protect one’s hard-earned financial foundation. We can provide
a review and analysis of clients’ current insurance coverage and will work with clients’ insurance
agent to coordinate coverage efforts. If a client does not have an insurance agent or company to
work with, we can provide referrals.
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Business Owners – it is not our intent to actively pursue business owners as clients, however, many
entrepreneurial individuals start small businesses (family limited partnerships, limited liability
companies, etc.) On occasion, business owners may seek advice on how to transition ownership to
family members, existing employees and/or unaffiliated interested buyers. An exit strategy is an
integral part of business planning, but not one that needs to be addressed right away. Often times
overlooked by business owners, we can provide or recommend consulting services and make
introductions to other professionals who can assist with proper business planning.
We encourage clients to review our recommendations and suggestions with their other professional
advisors, such as their attorney and accountant. After an appropriate amount of time, a follow-up
meeting is scheduled to discuss the specifics of the recommendations.
Personal finance covers a wide variety of money topics and understanding how each of these topics
work together is important for laying the groundwork for a solid financial foundation for clients and
families. Additionally, the appropriate referrals to tax, legal and/or insurance professionals will
be properly introduced. Although we have professional relationships with other service providers
and may from time to time offer referrals, it is always in the clients’ best interest to perform their
own due diligence on all referred advisors.
Item 5 – Fees and Compensation
An initial meeting is scheduled with a prospective client at no cost or obligation. The purpose of the
meeting is to gather information from the prospective client and to discuss the types of service we
provide.
Our fees are billed in arrears at the end of each calendar quarter based upon the value (market value
or fair market value in the absence of market value) of the client’s account. Covered call fees are
also billed in arrears. Fees will be debited from clients account in accordance with the client
authorization in their agreement with the custodian.
There are no additional fees for financial planning services.
On occasion, we may provide project work services and charge a one-time fee based on the time
commitment and level of complexity of the project. All fees will be agreed upon in a separate
statement which will become part of the Advisory Agreement. When we charge a client their fee
for advice or for a special project arrangement, the fees will be deducted directly from the client’s
account. Upon special request from the client, we may invoice the client directly.
Clients understand that other clients of ours may have different fee rates and payment plans for
similar services. We retain the discretion to negotiate alternative fees on a client-by-client basis.
Client facts, circumstances and needs are considered in determining the fee schedule. The
circumstances include the complexity of the client’s assets to manage, anticipated future additional
assets, related accounts, portfolio style, account composition and reports, among other factors.
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Discounts, not generally available to our advisory clients, may be offered to family members and
friends of associated persons of our firm. The specific annual fee schedule is identified in the
Advisory Agreement between us and each client. We may group related client accounts for the
purposes of achieving the minimum account size requirements for determining the annualized fee.
The annualized fee for Portfolio Management Services is charged as a percentage of assets under
management, according to the following schedule:
Equity and Balanced
(VEP, IEP, GEP, PIP, TGP & TVP) – AUM
First $1 Million
Next $1 Million to $5 Million
Next $5 Million and above
3rd Party Accounts (including covered call options)
Annual Fee
1.25% (0.0125)
1.00% (0.0100)
0.75% (0.0750)
0.50% (0.0500)
Annual Fee
0.50% (0.0050)
0.25% (0.0250)
0.15% (0.0015)
Options* – Equity - AUM
First $500,000
Next $500,000 and above
3rd Party Accounts
*in addition to VEP, IEP or GEP fee
Strategic Income Portfolio Program (SIPP) - AUM Annual Fee
First $1 Million
Next $1 Million to $5 Million
Next $5 Million and above
3rd Party Accounts
1.25% (0.0125)
1.00% (0.0100)
0.75% (0.0075)
0.25% (0.0025)
Since we bill quarterly in arrears, if a client terminates our services, we are entitled to collect fees
earned from the first day of the quarterly billing cycle through the date of termination. We do not
charge a termination fee, however a mutually agreed-upon fixed fee may apply if a special project is
requested by the client at the time of termination. We do not currently impose minimum account
requirements. If minimum account requirements were adopted, pre-existing advisory clients would
be subject to the agreement in place at the time client entered into the advisory relationship.
In addition to our fees, our investment advisory clients may pay asset -based fees to mutual funds,
wrapped fee programs, or separate account money managers for investment management.
Custodians may charge commissions and/or transaction fees. We do not receive any portion of those
fees. Clients are strongly encouraged to review all the fees charged by the funds, custodians, money
managers and us to fully understand the total amount paid.
TIA nor its owner, Street, accepts compensation for the sale of securities or other forms of
compensation. We have a bias towards “no-load” funds with no upfront, deferred, or annual sales
TIA Form ADV Parts 2A & 2B
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charges but may make exceptions based on our belief of the more suitable investment for our clients.
We believe these solutions are generally advantageous to our clients compared to funds with sales
charges.
Services from attorneys, accountants, insurance, and other professionals are paid directly by the
client.
Unless a client has received our disclosure brochure (ADV Part 2A and 2B) and Form CRS prior to
signing the investment advisory agreement, it may be terminated by the client within five (5) business
days of signing the agreement without incurring any advisory fees. After such time, either party may
terminate the agreement for any reason upon receipt of 30 days written notice.
Item 6 – Performance-Based Fees and Side-by-Side Management
We do not accept performance-based fees based upon a percentage of the capital appreciation of
assets. We may also invest personal money in the same investments as our clients if the investment
objectives, risk tolerance and other investment criteria are similar to those of the client. In such
cases, our personnel invests with the same third party pricing our clients receive. Our personnel
must report all required trades and security positions to the firm’s compliance consultant on a
quarterly basis.
Item 7 – Types of Clients
financial planning services are provided
Investment services and
to high-net-worth
individuals/families, charitable organizations, and small businesses. We also offer account
manament services to other investment firms. We do not have a minimum account size.
Item 8 – Methods of Analysis, Risk of Loss, and Investment Strategies
Methods of Analysis and Risk
Fundamental Analysis: We primarily use fundamental analysis in choosing securities for our
portfolios. We attempt to measure the intrinsic value of a security by looking at economic and
financial factors (including the overall economy, industry conditions and the financial condition and
management of the company itself) to determine if the company is underpriced (indicating it may be
a good time to buy) or overpriced (indicating it may be time to sell). We apply certain valuation
techniques that we have developed to determine the attractiveness of a security.
Fundamental analysis does not attempt to anticipate market movements. This presents a potential
risk, as the price of a security can move up or down along with the overall market regardless of the
economic and financial factors considered in evaluating the stock.
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Technical Analysis: We use technical analysis only as a supplement to our investment process.
Technical analysis analyzes past market movements and applies that analysis to the present in an
attempt to recognize recurring patterns of investor behavior and potentially predict future price
movement. We may use technical analysis in determining appropriate entry and exit points for
securities.
Technical analysis does not consider the underlying financial condition of a company. This presents
a risk in that a poorly managed or financially unsound company may underperform regardless of
market movement.
Qualitative Analysis: We subjectively evaluate non-quantifiable factors such as quality of
management, industry sector, management attitude towards shareholders, strength of research and
development factors not readily subject to measurement which help predict changes to share price
based on that data.
A risk in using qualitative analysis is that our subjective judgment may prove incorrect.
Mutual Fund and/or Exchange Traded Funds (“ETF”) Analysis: If mutual funds or ETF’s are
utilized, and this is not our primary strategy, we look at the experience and track record of the
manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an
ability to invest over a period of time and in different economic conditions. We also look at the
underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap
in the underlying investments held in other fund(s) in the client’s portfolio. We also monitor the
funds or ETFs in an attempt to determine if they are continuing to follow their stated investment
strategy.
A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance
does not guarantee future results. A manager who has been successful may not be able to replicate
that success in the future. In addition, as we do not control the underlying investments in a fund or
ETF, managers of different funds held by the client may purchase the same security, increasing the
risk to the client if that security were to fall in value. There is also a risk that a manager may deviate
from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s)
less suitable for the client’s portfolio.
Risks for all forms of analysis: Our securities analysis methods rely on the assumption that the
companies whose securities we purchase and sell, the rating agencies that review these securities,
and other publicly available sources of information about these securities, are providing accurate and
unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that
our analysis may be compromised by inaccurate or misleading information. Investing involves risk
of loss, including loss of principal, that clients must be prepared to bear.
We generally recommend traditional investment strategies for our clients. We first start by helping
clients determine an asset allocation, risk tolerance and investment strategy with which they are
comfortable. Our investment advisory services are delivered primarily through providing advice
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and consultation in the selection of appropriate portfolio strategies and managers to achieve the goals
established by our clients.
We tend to recommend strategies that we believe clients understand and tend to avoid more
exotic strategies, such as option trading, commodities, or futures. On occasion, clients may inquire
about non-traditional investment opportunities. Although not our stated area of expertise, we may
provide opinions or guidance, however, other professional advisors should be consulted prior to
engaging in any transactions.
Although not the most important factor for investment decisions, we manage portfolios with
thoughtful attention to the tax implication of transactions. We strive to be tax responsible, tax aware
and tax efficient. However, we are not accountants and therefore, recommend coordination of tax
strategy with one’s tax advisor.
We monitor our clients’ portfolios on a regular basis, and no less frequently than quarterly,
although market and other conditions may lead to more frequent reviews. We believe in quarterly
reviews because we do not want to change strategy or positions based on a bad month, especially
since such actions could produce adverse tax and financial consequences long term.
As with any investment strategy, a risk of loss exists, and clients must bear that risk. We attempt to
analyze the extent of the risk in a client’s portfolio and assist the client in determining if that degree
of risk is appropriate to the client’s investment objectives and risk tolerance. There is no guarantee
the model portfolios can, or will, achieve their stated goals and objectives, and past performance is
not indicative of future results.
Investment Strategies
Long-term purchases: Our primary strategy is to purchase securities with the idea of holding them
in the client's account for a year or longer. We employ this strategy when:
1. We believe the securities to be currently undervalued, and/or
2. We want exposure to a particular asset class or market sector over time, regardless of the
current projection for this class or sector.
A risk in a long-term purchase strategy is that by holding the security for this length of time, we may
not take advantage of short-term gains that could be profitable to a client. Moreover, if our
predictions are incorrect, a security may decline sharply in value before we make the decision to sell.
Short-term purchases: When utilizing this strategy, and this is not our primary strategy, we would
purchase securities with the idea of selling them within a relatively short time (typically a year or
less). We would do this in an attempt to take advantage of conditions that we believe will soon result
in a price swing in the securities we purchase.
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A short-term purchase strategy poses risks should the anticipated price swing not materialize; we are
then left with the option of having a long-term investment in a security that was designed to be a
short- term purchase or potentially taking a loss.
In addition, this strategy involves more frequent trading than does a longer-term strategy and could
result in increased brokerage and other transaction-related costs, as well as less favorable tax
treatment of short-term capital gains.
Option writing: We may use various types of options as an investment strategy. An option is a
contract that gives the buyer the right, but not the obligation, to buy or sell an asset (such as a share
of stock) at a specific price on or before a certain date. An option, just like a stock or bond, is a
security. An option is also a derivative because it derives its value from an underlying asset.
Currently, we use mainly "covered calls", in which we sell an option on a security already owned in
one’s portfolio. In this strategy, premiums are received for making the option available and the person
purchasing the option has the right to buy the security from you at an agreed-upon price on or before
the expiration date. We use this strategy as an additional source of income yield to our portfolios.
Other option strategies may be utilized on a case-by-case basis.
A risk of covered calls is that the price of the security you own may be higher than the price you
received under the option contract creating an opportunity loss on the option contract.
Another risk of covered calls is if we want to sell the underlying stock before the expiration date and
the option buyer has not exercised the option. In this case, we will have to buy back the option for a
possible loss.
Risk of Loss: Risk may include, but not be limited to, market risk, inflation, interest rate fluctuation,
underlying business risk, liquidity, and financial risk.
1. Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible
and intangible events and conditions. This type of risk is caused by external factors
independent of a security’s particular underlying circumstances. For example, political,
economic, and social conditions may trigger market events.
2. Inflation Risk: When inflation is present, a dollar today will not buy as much as a dollar next
year, because purchasing power is eroding at the rate of inflation.
3. Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For
example, when interest rates rise, yields on existing bonds become less attractive, causing
their market values to decline.
4. Business Risk: These risks are associated with a particular industry or a particular company
within an industry. For example, oil-drilling companies depend on finding oil and then
refining it, a lengthy process, before they can generate a profit. They carry a higher risk of
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profitability than an electric company, which generates its income from a steady stream of
customers who buy electricity no matter what the economic environment is like.
5. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally,
assets are more liquid if many traders are interested in a standardized product. For example,
Treasury Bills are highly liquid, while real estate properties are not.
6. Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of
profitability, because the company must meet the terms of its obligations in good times and
bad. During periods of financial stress, the inability to meet loan obligations may result in
bankruptcy and/or a declining market value.
As with any investment strategy, a risk of loss exists, and clients must bear that risk. We attempt to
analyze the extent of the risk in a client’s portfolio and assist the client in determining if that degree
of risk is appropriate to the client’s investment objectives and risk tolerance.
Item 9 – Disciplinary Information
TIA, nor its owner, are the subject to any legal or disciplinary actions or controversies. Refer to Part
2B Supplements for information pertaining to TIA’s associates.
Item 10 – Other Financial Industry Activities and Affiliations
TIA’s owner, Street, is the sole owner of Trust Investment Advisors Wealth Management, LLC (“TIA
WM”) and we may provide professional model portfolio management to TIA WM clients. We can
make referrals to other professionals such as attorneys, accountants, mortgage bankers, and
insurance agents that we believe would provide good service to our clients. Our relationships with
these professionals are always based on what we believe is best for the client. TIA is not affiliated
with any of the professionals it might recommend to clients. Although we have professional
relationships with other service providers and may from time to time offer referrals, it is always in
the clients’ best interest to perform their own due diligence on all referred advisors. TIA receives no
compensation or referral fees for any professional advisor we may recommend.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
We have a Code of Ethics that we will provide to any client or prospective client upon request. The
basic principle is that we are fiduciaries for our clients and are required to put their interests ahead
of our own in advising them. We do not recommend or purchase for client accounts securities in
which we have a financial interest.
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We sometimes invest in the same securities that we select for our clients. This only occurs when
the investment objectives, risk tolerance and other investment criteria are similar to those of the
client. We invest on the same terms, and we are subject to the same third-party pricing as our clients.
If purchases or sales are made for clients and for us on the same day, purchases and sales are made
first for client accounts.
We recommend a variety of investment vehicles to our clients. TIA, nor its owner, have any
affiliation with the underlying investment managers or recommended solutions providers. Nor does
TIA share in any fees or commissions. We have no financial relationships with issuers of securities.
For the purpose of establishing and implementing TIA clients’ financial plan, we will recommend
and work with other financial professionals, accountants, insurance agents and attorneys. TIA, nor
its owner, has any affiliation with accountants, insurance companies, its agents, or any attorneys
or law firms; nor does it share in any fees.
Our Code of Ethics includes policies that restrict employee equity transactions. Our Code of Ethics
further includes the firm's policy prohibiting the use of material non-public information. While we
do not believe that we have any access to non-public information, all employees are reminded that
such information may not be used in a personal or professional capacity.
TIA and individuals employed with our firm are prohibited from engaging in principal transactions.
Item 12 – Custodian/Brokerage Practices
For discretionary clients, we require clients to provide us with written authority to determine the
broker dealer/custodian to use for their transactions. Clients must also include any limitations on
discretionary authority in a written statement. Clients may change/amend these limitations as
required. Such amendments must be provided to us in writing.
As a matter of policy and practice, TIA utilizes block trades for client accounts. However, there are
times when we implement client transactions separately for each account. Consequently, certain
client trades may be executed before others at a different price.
We have an arrangement with National Financial Services LLC, Fidelity Investments, and Fidelity
Brokerage Services LLC (all affiliates, "Fidelity") through which Fidelity provides our firm with
their "platform" services. The platform services include, among others, brokerage, custodial,
administrative support, record keeping and related services that are intended to support
intermediaries like us in conducting business and in serving the best interests of our clients but that
may also benefit us.
Fidelity may charge brokerage commissions and transaction fees for effecting certain securities
transactions (i.e., Fidelity currently charges zero commission for accounts selecting to receive
electronic communication). Fidelity’s commission rates are generally considered discounted from
customary retail commission rates. However, the commissions and transaction fees charged by
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Fidelity may be higher or lower than those charged by other custodians and broker-dealers. As part
of the arrangement, Fidelity may also make available to our firm, at no additional charge to us,
including research services obtained by Fidelity directly from independent research companies. TIA,
nor its owner, share in any of brokerage/custodian fees or commissions. We may also receive
additional services which, without this arrangement, we might be compelled to purchase the same or
similar services at our own expense.
As a result of receiving such services for no additional cost, we may have an incentive to continue to
use or expand the use of Fidelity's services. We examined potential conflicts of interest when we
chose to enter into the relationship with Fidelity and have determined that the relationship is in the
best interests of our clients and satisfies our client obligations, including our duty to seek best
execution. In addition, we may use a broker dealer outside of Fidelity in certain situations. A client
may pay a commission that is higher than another qualified broker-dealer might charge to effect the
same transaction where we determine in good faith that the commission is reasonable in relation to
the value of the brokerage and research services received. In seeking best execution, the
determinative factor is not the lowest possible cost, but whether the transaction represents the best
qualitative execution, taking into consideration the full range of broker-dealer services, including the
value of research provided, execution capability, commission rates, and responsiveness. Accordingly,
while we seek competitive rates, to the benefit of all clients, we may not necessarily obtain the lowest
possible commission rates for specific client account transactions. Although the investment research
products and services that may be obtained by us will generally be used to service all of our clients,
a brokerage commission paid by a specific client may be used to pay for research that is not used in
managing that specific client’s account. TIA and Fidelity are not affiliated.
Item 13 – Review of Accounts
All financial plans and portfolios are reviewed on a periodic basis depending on numerous
factors including changes in personal circumstances such as marriage, the birth or adoption of a
child, divorce, significant financial changes, death, market conditions, investment strategy changes,
and a variety of other life events. Contact us if your personal circumstances have changed.
As a practical matter, client financial plans and portfolios may be reviewed on an informal basis
much more frequently depending on changes – expected and unexpected - to one’s personal
situation and/or market conditions.
Certain clients with accounts in excess of $250,000 will receive performance reports.
Clients will receive account statements, at least quarterly, directly from the custodian, either by mail
or electronically. Many of our clients have chosen to have direct access online to their accounts
through the custodian’s web portal.
We also attempt to have meetings with clients on a regular basis to discuss their portfolio and overall
status of their financial plan.
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We depend on our clients to make us aware of significant changes to their financial position.
Item 14 – Client Referrals and Other Compensation
We will pay referral fees to independent persons or firms ("Promoter") for introducing clients to us.
Whenever we pay a referral fee, we require the Promoter to provide the prospective client with a
copy of this document and a separate disclosure statement that includes the following information:
1. the Promoter's name and relationship with our firm;
2. the fact that the Promoter is being paid a referral fee;
3. the amount of the fee; and whether the fee paid to us by the client will be increased
above our normal fees to compensate the Promoter.
As a matter of firm practice, the advisory fees paid to us by clients referred by promoters are not
increased because of any referral.
It is our policy not to accept or allow our related persons to accept any form of compensation,
including cash, sales awards, or other prizes, from a non-client in conjunction with the advisory
services we provide to our clients.
Item 15 - Custody
TIA has custody of certain client assets due to provisions in an agreement that certain clients execute
with Fidelity Investments. These provisions provide TIA the authority to disburse funds from its
clients’ accounts on an ongoing basis without further approve to one more third parties as designated
by the clients.
Clients receive account statements directly from the custodian at least quarterly to assure that the
client is satisfied with our investment selections. Client assets are under the care of a reputable
third-party custodian. Our clients will receive statements either electronically or by US mail directly
from custodian; they do not flow-through us.
Item 16 – Investment Discretion
this authority by signing an Advisory Agreement.
We will
As a rule, we have discretionary authority to manage investments of clients. Our clients provide
approval for
implement
recommendations through a qualified custodian. We do not hold client assets. Clients will sign all
new account applications; we will not execute documents on behalf of our clients. We will not
manage a client’s portfolio without a signed Advisory Agreement.
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Item 17 – Voting Client Securities
We do not vote client securities. Clients will receive proxies and other solicitations directly from
the transfer agent or custodian. We will, however, provide guidance if requested.
Item 18 – Financial Information
TIA nor its owner, have any material negative financial information to report. We have discretionary
authority of client assets; however, we do not require the prepayment of fees.
Item 19 – Requirement for State-Registered Advisors
We are an SEC-registered firm; this Item is not applicable.
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Form ADV Part 2B –
Supplement
Item 1
Cover Page
Burton P. Street
Street Capital Partners, LLC
Trust Investment Advisors
bstreet@tiadvisors.com
Owner
CRD #2332253
This brochure supplement provides information about Burton P. Street that supplements the TIA
brochure. Please contact Sue Mitchell, compliance consultant, at smitchell@tiadvisors.com if you
have any questions about the contents in Part 2 of Form ADV or its Supplement.
Additional information is available on the SEC’s website at www.adviserinfo.sec.gov. We are
required to inform you that registration itself does not imply approval or a certain level of skill or
training.
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Item 2 – Education Background and Business Experience
Burton P. Street (“Street”) was born in 1968. He founded Street Capital Partners, LLC in April
2020, and in June 2020, acquired Trust Investment Advisors (“TIA”) with plans to maintain the
company’s culture and continue its proven investment philosophy. He brings over 25 years of
experience in the financial services industry. Street attended Hanover College and obtained a degree
in business administration. Street is the Chairman of TIA’s Investment Policy Committee.
In the fourth quarter of 2023, Street founded Trust Investment Advisors Wealth Management, LLC
(“TIA WM”). TIA WM is an independent registered investment advisory firm registered with the
SEC.
Prior to acquiring TIA, Street was employed by Trust and Investment Advisors, Inc., as a Senior
Vice President Portfolio Manager from March 2020 until May 2020. Prior to Trust and Investment
Advisors, Inc., Street was a discretionary portfolio manager with Robert W. Baird & Co. Inc.,
between August 2017 until February 2020. Prior to his employment with Baird, Street was a manager
for RBC Capital Markets, LLC from October 2004 until August 2017. Street held many FINRA
licenses including the Series 8 (General Securities Sales Supervisor), Series 3 (National Commodity
Futures), Series 7 (General Securities), Series 65 (Uniform Investment Advisor) and Series 63
(Uniform Securities Agent) and passed the Securities Industry Essentials examination. Street
currently holds an insurance license.
Item 3 – Disciplinary Information
There have not been any civil or criminal actions brought against Street, nor have there been any
administrative proceedings before the state, SEC, or other regulatory authority.
Item 4 – Other Business Activities
Street is the founder and owner of Trust Investment Advisors Wealth Management, LLC.
Item 5 – Additional Compensation
Street has no sources of compensation related to investment advisory services other than the
compensation received by client fees. He does not participate in revenue sharing or soft dollar
arrangements with any third-party.
Item 6 – Supervision
Street is the sole owner of TIA. Street hired independent compliance consultant, Sue Mitchell, to
oversee its compliance program and regulatory compliance requirements. Although Street does not
“report” to Sue, she will review certain practices within TIA, including a quarterly review of personal
investment transactions.
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Form ADV Part 2B –
Supplement
Item 1
Cover Page
J. Ronald DeLay
Investment Policy Committee Member
jrdelay@tiadvisors.com
CRD #6112727
This brochure supplement provides information about J. Ronald DeLay that supplements the TIA
brochure. Please contact Sue Mitchell, compliance consultant, at smitchell@tiadvisors.com if you
have any questions about the contents in Part 2 of Form ADV or its Supplement.
Additional information is available on the SEC’s website at www.adviserinfo.sec.gov. We are
required to inform you that registration itself does not imply approval or a certain level of skill or
training.
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Item 2 – Education Background and Business Experience
J. Ronald DeLay (“DeLay”) was born in 1954 and began his career with Trust and Investment
Advisors, Inc., in September 2012, as Portfolio Manager. In 2017, he became President and CEO.
In June 2020 when Burton P. Street purchased TIA, he remained with TIA as a Portfolio Manager.
In 2022, DeLay moved to Arkansas and remains part-time as Senior Vice President and member of
TIA’s Investment Policy Committee. Effective in 2024, DeLay retired as Senior Vice President but
remains as member of the Investment Policy Committee. He brings over 30 years of experience in
the financial services industry.
DeLay attended Iowa State University and obtained degrees in Finance and Economics and passed
the Series 65 (Uniform Investment Advisor Law Examination).
Item 3 – Disciplinary Information
There have not been any civil or criminal actions brought against DeLay, nor have there been any
administrative proceedings before the state, SEC, or other regulatory authority.
Item 4 – Other Business Activities
DeLay is not actively engaged in any outside business activities or occupation.
Item 5 – Additional Compensation
DeLay does not participate in revenue sharing or soft dollar arrangements with any third-party.
Item 6 – Supervision
Members of the Investment Policy Committee are supervised by Burton P. Street, Owner of TIA,
and Chairman of the Committee.
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Form ADV Part 2B –
Supplement
Item 1
Cover Page
G. Michael Prugh
Senior Vice President
Portfolio Manager
mprugh@tiadvisors.com
CRD #1689496
This brochure supplement provides information about G. Michael Prugh that supplements the TIA
brochure. Please contact Sue Mitchell, compliance consultant, at sem19@att.net if you have any
questions about the contents in Part 2 of Form ADV or its Supplement.
Additional information is available on the SEC’s website at www.adviserinfo.sec.gov. We are
required to inform you that registration itself does not imply approval or a certain level of skill or
training.
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Item 2 – Education Background and Business Experience
G. Michael Prugh (“Prugh”) was born in 1950 and began his career with Trust and Investment
Advisors, Inc., in 1992, as Senior Vice President and Portfolio Manager. In June 2020 when Burton
P. Street purchased TIA, he remained with TIA as a Portfolio Manager. Effective in 2024, Prugh
transitioned to a part-time position but continues to be a member of the Investment Policy
Committee. He has over 35 years of experience in the financial services industry.
Prugh attended Miami University and obtained a degree in Business Administration and Finance in
1972. In 1974, he obtained his MBA from Indiana University. He received designation as a Certified
Public Accountant (CPA) in 1977. He obtained a Graduate Degree in Banking from the Stonier
Graduate School of Banking in 1982.
Item 3 – Disciplinary Information
In 2015, the SEC sanctioned Prugh with a civil and administrative penalty for Trust and Investment
Advisors Inc’s., failure to correct deficiencies identified by the SEC during examinations. Prugh is
no longer responsible for operations management.
Item 4 – Other Business Activities
Prugh is not actively engaged in any outside business activities or occupation.
Item 5 – Additional Compensation
Prugh has no sources of compensation related to investment advisory services other than the
compensation received by client fees. He does not participate in revenue sharing or soft dollar
arrangements with any third-party.
Item 6 – Supervision
Prugh is supervised by Burton P. Street, Owner of TIA. Street hired independent compliance
consultant, Sue Mitchell, to oversee its compliance program and regulatory compliance
requirements. Although Prugh does not report to Sue, she will review certain practices within TIA,
including a quarterly review of personal investment transactions.
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Form ADV Part 2B –
Supplement
Item 1
Cover Page
Louis Paul Lukac
Senior Vice President
Portfolio Manager
llukac@tiadvisors.com
CRD #1040850
This brochure supplement provides information about Louis Lukac that supplements the TIA
brochure. Please contact Sue Mitchell, compliance consultant, at sem19@att.net if you have any
questions about the contents in Part 2 of Form ADV or its Supplement.
Additional information is available on the SEC’s website at www.adviserinfo.sec.gov. We are
required to inform you that registration itself does not imply approval or a certain level of skill or
training.
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Item 2 – Education Background and Business Experience
Louis Lukac (“Lukac”) was born in 1960 and began his career with TIA in July 2020. In addition
to his employment with TIA, Louis is a founder, managing principal and Chief Investment Officer
(“CIO”) at Trowbridge Capital Partners, LLC (“Trowbridge”). He is an active researcher of
quantitative investment strategies and oversees both firms’ research and portfolio management.
Lukac is an active member of TIA’s Investment Policy Committee.
Prior to TIA and Trowbridge, Lukac was the Director of Futures Research for Prudential Securities
and a long-time registered Commodity Trading Advisor. With over 25 years of industry experience,
Lukac is a graduate of Purdue University with a bachelor’s degree in General Management/Finance
and a master’s degree in Agricultural Economics. He has authored many journal articles on trading
system design and market efficiency issues.
Item 3 – Disciplinary Information
There have not been any civil or criminal actions brought against Lukac, nor have there been any
administrative proceedings before the state, SEC, or other regulatory authority.
Item 4 – Other Business Activities
Other than his ownership and responsibilities with Trowbridge, Lukac is not actively engaged in any
outside business activities or occupation.
Item 5 – Additional Compensation
Lukac may receive compensation related to his participation as founder, managing principal and
CIO. He does not participate in soft dollar arrangements.
Item 6 – Supervision
Lukac is supervised by Burton P. Street, Owner of TIA. Street hired independent compliance
consultant, Sue Mitchell to oversee its compliance program and regulatory compliance requirements.
Although Lukac does not report to Sue, she will review certain practices within TIA, including a
quarterly review of personal investment transactions.
TIA Form ADV Parts 2A & 2B
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Form ADV Part 2B –
Supplement
Item 1
Cover Page
Dawn E. Slaughter
Assistant Vice President
dslaughter@tiadvisors.com
CRD #6101710
This brochure supplement provides information about Dawn E. Slaughter that supplements the TIA
brochure. Please contact Sue Mitchell, compliance consultant, at sem19@att.net if you have any
questions about the contents in Part 2 of Form ADV or its Supplement.
Additional information is available on the SEC’s website at www.adviserinfo.sec.gov. We are
required to inform you that registration itself does not imply approval or a certain level of skill or
training.
TIA Form ADV Parts 2A & 2B
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TIA Form
ADV Parts
2A & 2B
Item 2 – Education Background and Business Experience
Dawn E. Slaughter (“Dawn”) was born in 1959 and began her career with Trust and Investment
Advisors in April 2001. She has over 25 years of experience in the financial service industry and
began her career with Chauner, Graver & Associates, Inc., as Investment Advisor in 1983. In June
2020, she remained with TIA and continues in her existing role. Currently an Assistant Vice
President and the Manager of Equity Trading and Covered Call Options, Dawn is also an active
member of the Investment Policy Committee.
Dawn attended Taylor University in Upland, Indiana and obtained a B.S. in Social Sciences and
obtained the Series 65 license in May 2014.
Item 3 – Disciplinary Information
There have not been any civil or criminal actions brought against Dawn, nor have there been any
administrative proceedings before the state, SEC, or other regulatory authority.
Item 4 – Other Business Activities
Dawn is not actively engaged in any outside business activities or occupation.
Item 5 – Additional Compensation
Dawn has no sources of compensation related to investment advisory services other than the salary
she earns through compensation received by client fees. She does not participate in revenue sharing
or soft dollar arrangements with any third- party.
Item 6 – Supervision
Dawn is supervised by Burton P. Street, Owner of TIA. Street hired independent compliance
consultant, Sue Mitchell, to oversee its compliance program and regulatory compliance
requirements. Although Dawn does not report to Sue, she will review certain practices within TIA,
including a quarterly review of personal investment transactions.
TIA Form ADV Parts 2A & 2B
SEM Originated 4-20 rev 8/2025
Page 34
TIA Form
ADV Parts
2A & 2B