Overview
- Headquarters
- New York, NY
- Average Client Assets
- $85.7 million
- Minimum Account Size
- $10,000,000
- SEC CRD Number
- 116959
Recent Rankings
Barron's 2024:
97
Fee Structure
Primary Fee Schedule (FORM ADV PART 2A - FIRM BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $10,000,000 | 1.00% |
| $10,000,001 | $20,000,000 | 0.75% |
| $20,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | Below minimum client size | |
| $5 million | Below minimum client size | |
| $10 million | $100,000 | 1.00% |
| $50 million | $325,000 | 0.65% |
| $100 million | $575,000 | 0.58% |
Clients
- HNW Share of Firm Assets
- 97.02%
- Total Client Accounts
- 1,366
- Discretionary Accounts
- 29
- Non-Discretionary Accounts
- 1,337
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Pooled Investment Vehicles, Pension Consulting, Investment Advisor Selection
Regulatory Filings
Primary Brochure: FORM ADV PART 2A - FIRM BROCHURE (2026-03-31)
View Document Text
Item 1 - Cover Page
TAG Associates LLC
810 Seventh Avenue, 7th Floor
New York, N.Y. 10019-5890
Main Phone Number: 212-275-1500
www.tagassoc.com
March 2026
This Brochure provides information about the qualifications and business practices of TAG
Associates LLC (the “Adviser”, “we”, “our” or TAG”). If you have any questions about the
contents of this Brochure, please contact us at the telephone number provided above. The
information in this Brochure has not been approved or verified by the United States
Securities and Exchange Commission (“SEC”) or by any state securities authority.
TAG Associates LLC is an investment adviser registered with the SEC. Registration of an
Investment Adviser does not imply any level of skill or training.
Additional information about TAG Associates LLC is available on the SEC’s website at
www.adviserinfo.sec.gov.
i
Item 2 - Material Changes
Since the last annual update filed in March 2025, no material changes have been made to this
brochure.
In the past we have offered or delivered information about our qualifications and business
practices to clients (“you”, “your”) on at least an annual basis. You will receive a summary of
any material changes to this and subsequent Brochures within 120 days of the close of our fiscal
year, which is on December 31st. We may also provide you with a new Brochure or other
ongoing disclosure information about material changes as necessary and without charge.
Currently, our Brochure may be requested by contacting Jorge Gonzalez at 212-275-1500.
ii
Item 3 – Table of Contents
Item 1 – Cover Page......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................. ii
Item 3 – Table of Contents............................................................................................................. iii
Item 4 – Advisory Business ............................................................................................................ 1
Item 5 – Fees and Compensation .................................................................................................... 9
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................. 12
Item 7 – Types of Clients .............................................................................................................. 14
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ...................................... 15
Item 9 – Disciplinary Information ................................................................................................ 21
Item 10 – Other Financial Industry Activities and Affiliations .................................................... 22
Item 11 – Code of Ethics............................................................................................................... 24
Item 12 – Brokerage Practices ...................................................................................................... 26
Item 13 – Review of Accounts...................................................................................................... 29
Item 14 – Client Referrals and Other Compensation .................................................................... 30
Item 15 – Custody ......................................................................................................................... 31
Item 16 – Investment Discretion................................................................................................... 32
Item 17 – Voting Client Securities ............................................................................................... 33
Item 18 – Financial Information ................................................................................................... 34
iii
Item 4 - Advisory Business
TAG Associates is a multi-client family office and portfolio management services adviser. Formed
in 1983, TAG has an experienced staff of approximately 71 people, including senior relationship
managers, portfolio management professionals, accountants, bookkeepers and administrators.
TAG is an investment advisor, a commodity trading advisor (“CTA”) and a commodity pool
operator (“CPO”). When the company was founded in 1983, the multi-client family office was a
relatively new and unproven concept.
The Principal Owner of TAG is TAG Associates Holdings, LLC, a Delaware limited liability
company, an entity majority owned by Gary L. Fuhrman and David Basner.
TAG Services
On January 1, 2002, TAG Associates LLC acquired all the operating business assets of, and
succeeded to the business of, TAG Associates, Ltd (“TAG Ltd”). All references below to activities
prior to January 1, 2002 were performed by TAG Ltd. All activities described after January 1, 2002
are performed by TAG Associates LLC.
TAG offers its clients either a comprehensive package of services (such clients are
“Comprehensive Wealth Management clients”) or, on a stand-alone basis, portfolio management
services (such clients are “Portfolio Management clients”). Comprehensive Wealth Management
clients receive both portfolio management services as well as other non-investment financial
management services. All of the Adviser’s services are customized to the individual needs of
TAG’s clients. The services TAG provides are outlined in the attached Exhibit A (at the end of
this Item 4): “Summary of Client Services.”
TAG Associates LLC provides investment management services and other financial advice and
services primarily to high-net-worth individuals. TAG does not issue publications or other reports
on a subscription or other fee basis.
When providing Portfolio Management services to its clients, TAG serves as an overall portfolio
manager. Its services include evaluating a client’s financial situation and needs, setting investment
goals and objectives and formulating an asset allocation strategy. TAG also discusses and assists
the client in evaluating any investment restrictions that the client may require for his or her
portfolio, such as prohibiting investments in certain securities or industries. Once consensus has
been reached with the client, TAG selects the investment managers, monitors strategies and
managers, reports periodically (no less than quarterly) on the results of the portfolio and makes
change recommendations as necessary. In addition, TAG provides financial management
services, tax planning and tax compliance services, and estate and trust planning. TAG has also
advised clients on derivative securities transactions such as collars, swaps, etc.
Clients generally appoint our firm as their investment adviser of record on specified accounts
(collectively, the “Accounts”). The Accounts consist of separate account(s) held by qualified
custodian(s) under the client’s name. The qualified custodians maintain physical custody of all
TAG Associates ADV Part 2A March 2026
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funds and securities of the Account, and the clients retain all rights of ownership (e.g., right to
withdraw securities or cash, exercise or delegate proxy voting and receive transaction
confirmations) of the Accounts. Refer to Item 12 – Brokerage Practices for more information.
The Accounts are managed by TAG based on the client’s financial situation, investment
objectives and risk tolerance. The Adviser actively monitors the Accounts and implements advice
by buying, selling, reinvesting, or holding securities, cash or other investments of the Accounts.
Refer to Item 16 – Investment Discretion for more information.
TAG will need to obtain certain information from the clients to determine their financial situation
and investment objectives. In the process of obtaining the information from the client, TAG may
provide ancillary financial planning and consultative services including asset allocation, risk
management and income tax planning. Such financial planning and consultative services are
intended to better understand your financial situation and design an investment portfolio
consistent with your long-term needs and goals.
Clients will be responsible for notifying the Adviser of any updates regarding their financial
situation, risk tolerance or investment objectives and whether they wish to impose or modify
existing investment restrictions; however TAG will contact you at least annually to discuss any
changes or updates regarding a client’s financial situation, risk tolerance or investment objectives.
TAG is always reasonably available to consult with clients regarding the status of their Accounts.
Clients have the ability to impose reasonable restrictions on the management of their accounts,
including the ability to instruct the Adviser not to purchase certain securities.
It is important that a client understands that TAG manages 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 taken 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 to be 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.
No Participation in 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 include portfolio management and/or advice
concerning the selection of other investment advisers) and the execution of client transactions.
We do not offer or participate in wrap-fee programs. All our services are provided on a non-wrap
fee basis which means fees and expenses for execution of client transactions charged by your
TAG Associates ADV Part 2A March 2026
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broker/dealer and/or custodian are billed directly to your account separately from our advisory
fees.
TAG’s assets under management as of December 31, 2025, totaled $7,067,528,406 of which
$319,062,567 is managed on a discretionary basis and $6,748,465,839 is managed on a non-
discretionary basis.
TAG-Managed Investment Entities
TAG Associates serves as the investment manager and TAG Portfolio Management Group LLC,
an affiliate, serves as the general partner or manager to a number of Funds of Funds (the “TAG
Funds”) for its clients and third-party investors.
All TAG Funds are exempt from registration under the Investment Company Act of 1940 (the
“Company Act”). For those Funds that are exempt companies under Section 3(c)(1) of the
Company Act, all investors must qualify as "Accredited Investors" within the meaning of
Regulation D under the Securities Act of 1933. For those Funds that are exempt companies under
Section 3(c)(7) of the Company Act, all investors must qualify as “Qualified Purchasers” under
the Company Act.
In 1999, TAG Ltd established the TAG Relative Value Onshore Fund, L.P. (the “Onshore Fund”)
(formerly the TAG Relative Value Client Fund, L.P.). The Adviser is the investment manager,
and an affiliate of the Adviser is the general partner. This partnership is a "fund of funds." It
allows TAG clients to participate in the underlying investments of the Onshore Fund.
In 2000, the TAG Relative Value Fund, L.P. was established for investors who are not clients of
the Adviser. This partnership was identical to the Onshore Fund, above, other than that the Adviser
and its affiliate received fees and compensation for serving as investment manager and general
partner of this partnership. The assets of TAG Relative Value Fund, L.P. were combined with the
assets of the Onshore Fund as of January 1, 2015. Investors in TAG Relative Value Fund, L.P.
became Class B Limited Partners of the Onshore Fund and the existing investors of the Onshore
Fund became Class A Limited Partners.
In 2001, the TAG Relative Value Offshore Fund Ltd. was established for investors who are
offshore or tax-exempt. The Adviser is the investment manager of the Fund. Investors that are not
clients of the Adviser compensate the Adviser for its investment management services.
In 2003, the TAG Master Relative Value Fund, LLC was reorganized to serve as a master fund to
its feeder funds. The Adviser is the investment manager and an affiliate of the Adviser is the
manager.
In 2005, the Adviser established the TAG Diversified Strategies Fund, L.P. of which the Adviser
is the investment manager and an affiliate of the Adviser is the general partner. This entity is a
"fund of funds". Investors that are not clients of the Adviser may invest in share classes that pay
TAG Associates ADV Part 2A March 2026
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the Adviser certain fees for serving as the investment manager of this partnership.
In 2008, the TAG Distressed Debt Fund II, LLC was established. This entity is a "fund of funds."
The Adviser is the investment manager and an affiliate of the Adviser is the manager. It allows
investors to invest in certain underlying partnerships that the Adviser has identified as attractive
investments. Investors that are not clients of the Adviser compensate the Adviser and its affiliate
for its investment management services. The Fund is not accepting new capital.
In 2010, the TAG Distressed Debt Fund III, LLC was established. This entity is a “fund of funds.”
The Adviser is the investment manager and an affiliate of the Adviser is the manager. It allows
investors (client and non-client) to invest in certain underlying partnerships that the Adviser has
identified as attractive investments. Investors that are not clients of the Adviser compensate the
Adviser and its affiliate for its investment management services. The Fund is not accepting new
capital.
In 2015 the TAG Yield Opportunities Fund, LLC was established. This entity is a “fund of funds.”
The Adviser is the investment manager and an affiliate of the Adviser is the manager. It allows
investors to invest in certain underlying partnerships that the Adviser has identified as attractive
investments. Investors that are not clients of the Adviser compensate the Adviser for its investment
management services. The Fund is not accepting new capital.
In 2020 the TAG Dislocation & Recovery Fund Series of TAG Series Fund, LLC was established.
This entity is a “fund of funds.” The Adviser is the investment manager and an affiliate of the
Adviser is the manager. It allows investors to invest in certain underlying partnerships that the
Adviser has identified as attractive investments. Investors that are not clients of the Adviser
compensate the Adviser for its investment management services. The Fund is not accepting new
capital.
In 2021 the TAG Blockchain Opportunities Fund Series of TAG Series Fund, LLC was
established. This entity is a “fund of funds.” The Adviser is the investment manager and an affiliate
of the Adviser is the manager. It allows investors to invest in certain underlying partnerships that
the Adviser has identified as attractive investments. Investors that are not clients of the Adviser
compensate the Adviser and its affiliate for its investment management services. The Fund is not
accepting new capital.
In 2024 the TAG Credit Opportunities Fund Series of TAG Series Fund LLC was established.
This entity is a “fund of funds.” The Adviser is the investment manager and an affiliate of the
Adviser is the manager. It allows investors to invest in certain underlying partnerships that the
Adviser has identified as attractive investments. Investors that are not clients of the Adviser
compensate the Adviser and its affiliate for its investment management services. The TAG Credit
Opportunities Fund Series of TAG Series Fund LLC had its First Closing in February of 2025.
The Adviser and its affiliates do not charge the Adviser's clients that invest in any of the above
mentioned Funds any additional fees, or earn other compensation for serving as investment
manager, manager or general partner of such Funds. Clients of the Adviser pay for investment
TAG Associates ADV Part 2A March 2026
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management services based on separate agreements with the Adviser. In all cases, each investor
must meet the required relevant investor suitability standards.
The Adviser may, from time to time, consider offering interests in additional similarly structured
investment vehicles. This would provide the Adviser with an opportunity to present investment
opportunities to its clients in which they would not otherwise participate. The dual-class structure
of the investment vehicles affords the Adviser an opportunity to be compensated by non-clients
for its efforts in identifying, structuring and organizing such investment vehicles.
Please refer to Item 10 and Item 11 of this brochure for more information.
[Exhibit A appears on the next three (3) pages.]
TAG Associates ADV Part 2A March 2026
5
TAG ASSOCIATES, LLC
Summary of Client Services
Form ADV, Part 2 – Advisory
Business (Item 4) Exhibit A
PORTFOLIO MANAGEMENT
Planning
Implementation
Monitoring
Produce portfolio reports
Select investment managers
Set investment goals &
objectives
Formalize an
Design investment reporting
o Typically monthly or
quarterly
system
appropriate asset
allocation strategy
o On an absolute dollar
return basis
Provide benchmarks to
measure performance
o On a relative basis
versus similar
managers & indexes
Consider changes in strategy,
managers, etc.
TAG Associates ADV Part 2A March 2026
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FINANCIAL MANAGEMENT
Produce financial reports
Consider asset/liability
Design customized financial
oriented issues
reporting system
Update versus projections, etc.
o Need for
liquidity, etc.
o Focus on highlighting
tax issues, liquidity
needs, etc.
Establish banking/credit
Communicate results to
Asset cash flow
considerations
relationships
appropriate third party advisors
Plan for large tax
payments, etc.
Review hedging options
o One large block
of stock, etc.
TAX RELATED
Consider changes in:
Manage IRS and state tax
Identify tax savings
opportunities
audits
Prepare periodic tax
Periodically review estate
o Tax laws
projections
plan
Investment related
Prepare tax returns
o Investment products
o Interfamily driven
o Business relationships
o Residence driven
o Employee benefit plans
o Transaction driven
o Family relationships
TAG Associates ADV Part 2A March 2026
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ADMINISTRATIVE/
CONTROLLERSHIP
Select advisors/systems
Consider changes in:
Consider asset/liability
management techniques
Pay bills/Collect receipts
o Insurance
o New products/services
alternatives
Handle domestic staff
o Custodial
o Personal circumstances
alternatives
Negotiate house
o Cash management
systems
o Professional
relationships
closing, mortgages
Manage “the process”
Revisit “the process”
Determine optimum
information flow
o Which
o Right People
professionals?
o What information?
o Right Information
o Right time
o In what time
frame?
TAG Associates ADV Part 2A March 2026
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Item 5 - Fees and Compensation
TAG offers its clients two sets of services and fee arrangements: (1) Comprehensive Wealth
Management services, and (2) Portfolio Management services. Fees may vary from the stated fee
schedule and are subject to negotiation.
TAG is objective in its recommendations regarding the selection and retention of investment
managers and other professionals when choosing investment products and developing strategies
for our clients.
TAG does not accept any direct or indirect payments from other professionals it may hire on
behalf of its clients. Clients will, however, pay investment advisory fees to investment managers
in addition to fees payable to TAG for non-affiliated fund investments, as well as any customary
brokerage and related fees.
Separate management and performance-based fees are charged to investors who are not clients
of the Adviser who invest in some of the funds of funds it manages. Additional information on
these TAG Funds is available in Item 4.
TAG charges an annual retainer for its Comprehensive Wealth Management services under
which the client is provided with portfolio management, tax and/or financial advisory services.
The fee for tax and for advisory services is based upon an analysis of the volume and complexity
of the client's financial affairs. Comprehensive Wealth Management clients may also pay a fee
that is based on a percentage of assets under management for portfolio management services. In
some cases a fixed fee is negotiated for all services. TAG’s stated minimum fee for
Comprehensive Wealth Management services is $150,000 per year. The specific manner in
which fees are charged is established in each client’s written agreement with TAG.
The annual portfolio management fee for stand-alone Portfolio Management clients is based on
a percentage of assets under management. This fee is applied to currently investable assets only.
The stated fee schedule, when calculated based on assets under management, is as follows:
Assets under Management
Annual Fee
First $10 Million
Next $10 Million
Assets above $20 Million
1.00%
0.75%
0.50%
TAG Associates ADV Part 2A March 2026
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Payment of TAG’s fees can be made directly by the client or can be deducted from the client’s
account(s), if any, holding the client’s securities and funds. Fees deducted from an account are
paid directly to TAG by the qualified custodian of the client’s account(s). When fees are
deducted from an account, TAG will send the client a fee billing notice at approximately the
same time that TAG sends the fee-debit instructions to the qualified custodian. The fee billing
notice will reflect the specific manner in which the fee was calculated. The actual fee debited
from an account will appear on the client’s account statements sent to the client directly from
the qualified custodian. Clients should review the account statements received directly from the
qualified custodian and verify that the appropriate investment advisory fees are being deducted.
The qualified custodians of the account(s) do not verify the accuracy of TAG’s fees deducted
from an account. Fees and payment terms for special projects are negotiated separately.
This management fee is payable quarterly during the quarter in which the fees are incurred. (For
example, the bill sent to a client on February 15 relates to the quarter beginning January 1 and
ending March 31.) The fee is based on the net asset value of the assets being managed on the
closing of the last day of the preceding quarter (for example, the fee on February 15 is based on
the net asset values on December 31 of the preceding quarter). Billings for partial quarters, in a
start-up mode or in a termination mode are pro-rated based on the number of days during which
the services are rendered. Under the Portfolio Management Agreement, the Adviser does not
receive any other fees or payments, either from the client or any third party, in connection with
providing such services.
Other Fees & Expenses. Brokerage expenses and/or transaction fees charged by the qualified
custodian are billed directly to the client by the qualified custodian. TAG does not receive any
portion of such fees from you or the qualified custodian. In addition, you will incur certain
charges imposed by third parties other than TAG in connection with investments made through
your account including, but not limited to, mutual fund sales loads, 12b-1 fees and surrender
charges, variable annuity fees and surrender charges, IRA and qualified retirement plan fees,
and other charges imposed by the qualified custodian(s) of your account. Management fees
charged by TAG are separate and distinct from the fees and expenses charged by investment
company securities that may be recommended to you. A description of these fees and expenses
is available in each investment company security’s prospectus. We do not receive any portion
of such fees and expenses. Refer to Item 12 for more information about our brokerage
arrangements.
Non-Client Investors in TAG Managed Funds of Funds
Separately, TAG and TAG Portfolio Management Group charge investors who are not clients of
the Adviser management and performance-based fees on some of the funds of funds it manages.
These TAG Funds are identified in Item 4. Investors that are not clients of TAG Associates with
investments in TAG Diversified Strategies Fund and the TAG Relative Value Funds pay
management fees quarterly in advance, unless other fee arrangements have been made. Investors
that are not clients of the Advisor in the TAG Distressed Debt Funds, TAG Yield Opportunities
Fund, TAG Dislocation & Recovery Fund Series of TAG Series Fund, TAG Blockchain
Opportunities Fund Series of TAG Series Fund, and the TAG Credit Opportunities Fund Series
of TAG Series Fund pay management fees quarterly in arrears. The stated management fees
charged to non-client investors of the TAG Funds range from 0.75% to 1.25% on an annualized
basis. The Adviser may waive or reduce the management fee with respect to any investor in its
TAG Associates ADV Part 2A March 2026
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sole discretion. Before making an investment in any such TAG Fund, each prospective investor
(client or non-client of TAG) is provided with a copy of the Fund’s subscription agreement,
Private Placement Memorandum, Limited Partnership Agreement, Limited Liability Company
Agreement and/or Series Supplement (applicable to each such Fund – collectively referred to as
the “Subscription Documents”) that detail the fee arrangements charged to non-clients of the
Adviser. See Item 6 for a further explanation of the performance-based fees charged to investors
that are not clients of TAG in such TAG Funds.
Item 12 further describes the factors that TAG considers in selecting or recommending broker-
dealers for client transactions and determining the reasonableness of their compensation (e.g.,
commissions).
TAG Associates ADV Part 2A March 2026
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Item 6 - Performance-Based Fees and Side-By-Side Management
Performance-based fees are fees based on a share of capital gains on, or capital appreciation
of, the assets of an investor. Non-client investors (non-clients of the Adviser) of the following
funds pay performance-based fees:
TAG Relative Value Onshore Fund, L.P.: Class B Limited Partners (“Incentive
Allocation”)
TAG Relative Value Offshore Fund, Ltd.: share classes AA and BB (“Incentive Fees”)
TAG Distressed Debt Fund II, LLC and TAG Distressed Debt Fund III, LLC: Class B
Members (“Carried Interest”)
TAG Blockchain Opportunities Fund Series of TAG Series Fund, LLC: Class B and C
Members (“Incentive Distribution”)
Before making an investment in any such TAG Fund, each prospective investor is provided with
a copy of the Subscription Documents that detail the performance-based fee arrangements
charged to non-client investors of such TAG Fund (generally a 10% incentive fee or a 10%
carried interest). These performance-based fees are subject to hurdle-rates and high-water
marks. TAG structures any performance or incentive fee arrangement in conformity with the
requirements of Section 205(a)(1) of the Investment Advisers Act of 1940. Since these investors
are not TAG clients, they also pay management fees as stated in the Subscription Documents of
such TAG Funds.
As noted in the Subscription Documents of the TAG Funds, performance-based fees create an
incentive for the General Partner/Manager or the Investment Manager of each such Fund to
make investments that are riskier or more speculative than would be the case in the absence of
performance-based fees. The Subscription Documents of each TAG Fund detail the fee
arrangements, risk factors and potential conflicts of interest applicable to such TAG Fund,
including risks associated with performance fees charged by underlying managers of such TAG
Funds.
There are conflicts of interests that TAG faces by managing performance based accounts at the
same time as managing asset based, non-performance based accounts. For example, the nature
of a performance fee poses an opportunity for TAG to earn more compensation than under a
stand-alone asset based fee. Consequently, TAG has an incentive to favor performance fee
accounts over those accounts where we receive only an asset based fee. One way TAG could
favor performance fee accounts is that we may devote more time and attention to performance
fee accounts than to accounts under an asset based fee arrangement. It should be noted that a
relatively small percentage of investors in the TAG Funds are non-client investors subject to
performance based fees.
We do not impose a performance based fee to TAG clients who have invested in the TAG
Funds.
Performance fees can cause an investment adviser to engage in transactions or strategies which
TAG Associates ADV Part 2A March 2026
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will increase the amount of the performance fees. A performance fee may also encourage TAG
to make riskier and more speculative investments. TAG does not represent that the amount of
the performance fees or the manner of calculating the performance fees is consistent with other
performance related fees charged by other investment advisers under the same or similar
circumstances. The performance fees charged by TAG may be higher than the performance
fees charged by other investment advisers for the same or similar services.
TAG has established policies and procedures to address the various conflicts of interest
associated with charging a performance fee:
TAG does not devote additional time to the management of performance fee accounts
as compared to asset based fee accounts
Only non-client investors that are able to assume additional risk are solicited to engage
in a performance fee arrangement. TAG provides such non-client investors full
disclosure of the additional risks associated with a performance fee arrangement.
Non-client investors eligible to be charged a performance based fee must reach a pre-
determined and agreed upon high-water mark before the performance based fee is
charged.
Performance based fee arrangements of the Adviser will comply with Section 205(e) of the
Investment Advisers Act of 1940. According to Section 205(e) (see Rule 205-3 thereunder),
only investors meeting the SEC's definition of "qualified clients" may enter into agreements
providing for performance based compensation to TAG. A natural person or company must
meet one of the following conditions to be considered a qualified client:
Have at least $1,100,000 under management with TAG at the time the client enters into
an agreement with TAG; or
Provide documentation to the Adviser so that TAG will reasonably believe the client
has either a net worth of $2,200,000 or is a qualified purchaser under Section
2(a)(51)(A) of the Investment Company Act.
TAG Associates ADV Part 2A March 2026
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Item 7 - Types of Clients
TAG Associates LLC provides investment management services and other financial advice and
services primarily to high-net-worth individuals. TAG also provides such services to trusts,
estates, endowments, foundations, and other business entities of such high-net-worth individuals.
TAG identifies such client-family entities together with high-net-worth individuals when defining
types of clients on its ADV Part 1. In essence, TAG views individual families and their associated
entities as single clients when offering its multi-family wealth management services.
TAG also provides investment advice to a pension plan and a 401k plan.
Clients of TAG must be Qualified Clients - defined as an individual with at least $1.1 million in
assets under management with TAG immediately after entering into an investment advisory
contract with TAG or an individual with a net worth of $2.2 million or more, either individually
or jointly with a spouse, not including the value of their primary residence.
Generally, the minimum investment amount for opening accounts by new clients is $10
million. The Adviser does not require that clients retain a minimum account size.
TAG Associates ADV Part 2A March 2026
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Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
INVESTING IN SECURITIES AND OTHER ASSETS INVOLVES RISK OF LOSS
THAT CLIENTS SHOULD BE PREPARED TO BEAR.
In formulating investment strategies, capital preservation is TAG’s paramount consideration.
Portfolio Information - Data Sources
TAG currently utilizes the following computer software and databases in evaluating various
investment products as follows:
eVestment is a leading institutional investment database for asset manager research and
analytics. The software is cloud-based and acts as a repository of manager information. TAG
utilizes the eVestment platform to perform manager evaluation, comparisons, and analytics.
Morningstar provides qualitative and quantitative information/data on approximately 33,000+
Mutual Funds, ETFs, and Closed End Funds. Morningstar data feeds directly into eVestment
and may be used for manager research within the eVestment platform.
Hedge Fund Research (“HFR”) is a leading hedge fund data provider with proprietary indices
and peer-benchmarking. The platform’s benchmarks are considered an institutional industry
standard in fund performance analysis. HFR data feeds directly into eVestment and may be
used for manager research within the eVestment platform.
eVestment also provides qualitative and quantitative information covering 50,000+ records of
investment limited partnerships, registered investment advisor management organizations, and
indices.
The bulk of the information used to conduct manager research and evaluation is extracted from
either eVestment, HFR, or Morningstar. However, in some instances TAG obtains
information directly from various investment limited partnerships and managed account
managers which is also housed in the eVestment platform.
TAG utilizes a Bloomberg Terminal to access financial and other news in real-time format, as
well as business-related data, analytics, and research tools. TAG believes Bloomberg is one of
the most comprehensive sources of timely, daily business and financial information available.
SS&C Black Diamond Wealth Platform is a cloud-based solution to delivering performance
reporting and an immersive client portal. The platform offers daily reconciliation service,
reconciling data directly from custodial partners through Advent Custodial Data (ACD) feeds.
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TAG utilizes the SS&C Black Diamond Wealth Platform to aggregate asset valuations of our
clients’ diverse investment portfolios to produce performance reports. Asset pricing is
downloaded through the Black Diamond/Advent Direct Network’s ACD feeds for a majority
of our client’s brokerage accounts. Pricing information, for assets not available through the
ACD feeds, is provided through Advent/ICE Data Services. Index information is provided
through Advent/ICE Data Services, Black Diamond, Bloomberg, and HFR. Additionally, the
SS&C Black Diamond Wealth Platform offers a two-way vault where clients can securely
access account information and performance reports.
Investment Strategies
In general, TAG Associates serves as an overall portfolio manager. The Adviser’s services
include setting investment goals and objectives and formulating an asset allocation strategy for
our clients based on their financial situation and needs, together with establishing investment
objectives and restrictions (if any). There are situations where investment restrictions required by
a particular client may increase the portfolio’s risk and these are discussed with the client before
implementation. Once consensus has been reached with the client, TAG recommends the
investment managers, monitors the strategies and managers, reports periodically (no less than
quarterly) on the results of the portfolio and makes change recommendations as necessary.
Certain clients also engage TAG to provide financial management services, tax planning and
compliance services and estate and trust planning as part of offering overall wealth management
services to those clients.
In establishing investment goals for TAG clients, we consult financial newspapers and
magazines, research materials prepared by others, corporate rating services and the portfolio
information data sources discussed above. Where appropriate to a particular client’s investment
goals, TAG engages in classic security analysis of evaluating the expected performance of a
particular security or type of investment. To implement TAG’s investments strategies, clients
are introduced and will engage traditional third-party managers of stocks and/or bonds,
including mutual funds. Long-term investment recommendations often include subscriptions to
hedge funds or private equity managers, including TAG Funds managed by the Adviser and
discussed in Item 4 above.
On occasion, TAG recommends short term purchases of securities sold within a year; trading in
securities sold within 30 days; offsetting trading strategies; margin transactions; option writing,
including covered options, uncovered options or spread strategies.
Suitability Considerations
As a firm, TAG constantly seeks to identify portfolio managers whose investment mandates are
suitable for its clients in general. Prior to selecting any manager, TAG conducts due diligence on
the manager’s portfolios and performance, background and experience. Once selected as suitable
for TAG Associates’ clients, in general, we monitor their portfolio management and
performance, including, without limitation, any material changes in policies, procedures and
performance.
After TAG’s assessment of a client’s financial situation and investment objectives, it
recommends a number of investment managers we believe suitable for that client’s
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circumstances. As specified above, these third-party managers include mutual funds, traditional
managed account managers of stocks and bonds, hedge fund managers and/or private equity
managers. Once the client invests with the investment manager(s), TAG monitors the account to
verify that its client’s selected investment strategy is being implemented and tracks the manager’s
overall performance. This includes reviewing a particular client’s account periodically. TAG
also assesses whether adjustments are needed due to changes in the particular client’s
circumstances or the manager’s ability to accommodate client investment goals and restrictions.
In some instances, TAG may determine that a particular portfolio manager no longer meets its
investment criteria or can no longer effectively manage funds for the kinds of clients it services.
If that were to occur, TAG would recommend that some or all of its clients redeem their
investments in such manager, recognizing that redemptions may be limited due to various
restrictions on withdrawals such fund may have in place. Nonetheless, a client may elect to
remain with that particular manager, despite the Adviser’s recommendation to redeem.
Risk of Loss
Most private fund documents, including those of the TAG Funds and other investment Funds
recommended by TAG, state: “Investments in Funds are speculative, illiquid and involve a high
degree of risk.”
The multi-manager approach recommended by TAG to its clients is designed to lessen portfolio
volatility by investing with managers who employ diverse investment styles, including, without
limitation, managers who have the ability and mandate to engage in short sales, which generally
have the potential to be profitable in down markets. Prior to investing in any manager, TAG
reviews with its client the various strategies that may be employed by such third-party manager it
recommends, as well as the risks of such investments. TAG provides its clients with the offering
documents that describe the investment strategies and risks of such third-party managers.
Past performance is not indicative of future results. Therefore, you should never assume that
future performance of any specific investment or investment strategy will be profitable. Investing
in securities (including stocks, mutual funds, and bonds, etc.) involves risk of loss. Further,
depending on the different types of investments there may be varying degrees of risk. You should
be prepared to bear investment loss including loss of original principal.
Because of the inherent risk of loss associated with investing, TAG is unable to represent,
guarantee, or even imply that our services and methods of analysis can or will predict future
results, successfully identify market tops or bottoms, or insulate you from losses due to market
corrections or declines. The following does not purport to be a comprehensive summary of all of
the risks associated with investments in any particular strategy or fund. There are certain
additional risks associated with investing in securities through our investment management
program, as described below:
Investments classified as "alternative investments" may include a broad range of
underlying assets including, but not limited to, hedge funds, private equity, venture
capital, and registered, publicly traded securities. Alternative investments are
speculative, not suitable for all clients and intended for only experienced and
sophisticated investors who are willing to bear the high risk of the investment, which can
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include: loss of all or a substantial portion of the investment due to leveraging, short-
selling, or other speculative investment practices; lack of liquidity in that there may be
no secondary market for the fund and none expected to develop; volatility of returns;
potential for restrictions on transferring interest in the fund; potential lack of
diversification and resulting higher risk due to concentration of trading authority with a
single advisor; absence of information regarding valuations and pricing; potential for
delays in tax reporting; less regulation and typically higher fees than other investment
options such as mutual funds. The SEC requires investors be accredited to invest in these
more speculative alternative investments. Investing in a fund that concentrates its
investments in a few holdings may involve heightened risk and result in greater price
volatility.
Private Equity – Direct investments in private companies are highly speculative and
involve significant risks including but not limited to: Entering any transaction may result
in the return of less than your original investment, or even a total loss of the investment;
Illiquidity of investment; Possible lack of diversification; Financial market fluctuations;
Financial leverage risk; Control issues; Economic, political, legal and currency risks;
Possible lack of operating history; and Risks in connection to accuracy of financial
reporting.
Market Risk – Either the stock market as a whole, or the value of an individual company,
goes down resulting in a decrease in the value of client investments. This is also referred
to as systemic risk.
Equity (stock) market risk – Common stocks are susceptible to general stock market
fluctuations and to volatile increases and decreases in value as market confidence in and
perceptions of their issuers change. If you held common stock, or common stock
equivalents, of any given issuer, you would generally be exposed to greater risk than if
you held preferred stocks and debt obligations of the issuer.
Company Risk. When investing in stock positions, there is always a certain level of
company or industry specific risk that is inherent in each investment. This is also referred
to as unsystematic risk and can be reduced through appropriate diversification. There is
the risk that a company will perform poorly or have its value reduced based on factors
specific to that company or its industry. For example, if a company’s employees go on
strike or the company receives unfavorable media attention for its actions, the value of
the company may be reduced.
Fixed Income Risk. When investing in bonds, there is the risk that the issuer will default
on the bond and be unable to make payments. Further, individuals who depend on set
amounts of periodically paid income face the risk that inflation will erode their spending
power. Fixed-income investors receive set, regular payments that face the same inflation
risk.
Options Risk. Options on securities may be subject to greater fluctuations in value than
an investment in the underlying securities. Purchasing and writing put and call options
are highly specialized activities and entail greater than ordinary investment risks.
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ETF and Mutual Fund Risk – When investing in an ETF or mutual fund, you will bear
additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating
expenses, including the potential duplication of management fees. The risk of owning
an ETF or mutual fund generally reflects the risks of owning the underlying securities
the ETF or mutual fund holds. You will also incur brokerage costs when purchasing
ETFs.
Management Risk – Your investment with our firm varies with the success and failure
of our investment strategies, research, analysis and determination of portfolio securities.
If our investment strategies do not produce the expected returns, the value of the
investment will decrease.
Reliance on Underlying Managers – The Adviser invests on behalf of clients in funds
and companies sponsored and managed by third parties. In such cases, the Adviser does
not have an active role in the management of the assets of the underlying funds or
companies, including the valuation by the underlying funds of their investments. The
Adviser’s ability to withdraw from or transfer interests in such funds and companies may
be limited. Further, the performance of each such investment made by the Adviser
depends significantly on decisions made by third parties, which could adversely affect
the returns achieved by the Adviser.
Margin Risk - When you purchase securities, you may pay for the securities in full or
borrow part of the purchase price from your account custodian or clearing firm. If you
intended to borrow funds in connection with your Account, you will be required to open
a margin account, which will be carried by the clearing firm. The securities purchased
in such an account are the clearing firm’s collateral for its loan to you.
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 your account.
It is important that you fully understand the risks involved in trading securities on
margin, which are applicable to any margin account that you maintain as part of your
brokerage account.
These risks include the following:
o You can lose more funds than you deposit in your margin account.
o The account custodian or clearing firm can force the sale of securities or other
assets in your account.
o The account custodian or clearing firm can sell your securities or other assets
without contacting you.
o You are not entitled to choose which securities or other assets in your margin
account may be liquidated or sold to meet a margin call.
o The account custodian or clearing firm may move securities held in your cash
account to your margin account and pledge the transferred securities.
o The account custodian or clearing firm can increase its “house” maintenance
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margin requirements at any time and they are not required to provide you advance
written notice.
o You are not entitled to an extension of time on a margin call.
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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.
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Item 10 - Other Financial Industry Activities and Affiliations
As detailed in Item 4, above, TAG provides products or services other than investment advice to
clients.
TAG is registered with the National Futures Association (“NFA”) as a commodity trading
advisor (“CTA”) and commodity pool operator (“CPO”).
TAG registered with the NFA because it operates certain TAG Funds of Funds (“TAG Funds”)
that met the definition of commodity pools. The Adviser is registered as a 4.7 exempt CTA.
Note that some TAG Funds are exempt from registration under rule 4.13(a)(3).
In addition, David Basner, Gary L. Fuhrman, Jeffrey Tumolo, John Pantowich, Ted
Katramados, Neil Shapiro, and Jorge Gonzalez are registered as associated persons of TAG.
Each is also registered as an associated person with an affiliate, TAG Portfolio Management
Group, LLC, which is registered with the NFA as a commodity pool operator.
GF Capital Asset Advisors LLC (“GF Capital”) is under common ownership with TAG
Associates. GF Capital, a registered investment adviser, and its affiliated investment entities
provide “investment supervisory services” to their clients, which consist of private investment-
related funds. GF Capital was formed in 2005, but did not commence operations as a registered
investment adviser until February 2012. GF Capital is controlled by its manager and 100%
owner, GF Capital Management & Advisors, LLC. Additional information concerning GF
Capital Asset Advisors, LLC (CRD #160144) can be found on the Securities and Exchange
Commission’s website at www.adviserinfo.sec.gov.
TAG Associates Florida LLC (“TAG Florida”) is an investment adviser and is under common
ownership with TAG Associates. Through TAG Florida’s affiliation with TAG, TAG Florida
will be able to offer its clients access to the TAG Funds.
Personnel of TAG Associates, TAG Florida, and GF Capital may offer or introduce the products
and services of its affiliated and unaffiliated entities without limitation if the services and
products are deemed to be suitable and appropriate. For the avoidance of doubt, clients and/or
investors of TAG Associates or TAG Florida may also be clients and/or investors in GF Capital
funds, products and services and vice versa.
The fact that we share personnel with our affiliated companies creates a conflict of interest
because they split their time between TAG Associates, TAG Florida and GF Capital. To
mitigate the conflict of interest, GF Capital hires personnel that work exclusively for GF Capital
and do not work for TAG Associates or TAG Florida. Moreover, allocation of resources,
including personnel, employees and consultants and similar resources, among TAG Associates,
TAG Florida, TAG Funds, GF Capital and GF Capital Funds is made by factoring the overall
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fiduciary duty all affiliated companies have to their clients, subject to applicable law, including
the fiduciary duty owed by TAG Associates to its clients and to its TAG Funds. TAG
Associates and TAG Florida pursue different investment objectives and strategies for their
advisory clients than GF Capital and its Managers pursue for GF Capital Funds. We do not
expect that shared personnel between and among GF Capital, TAG Associates and TAG Florida
will raise material allocation issues between the GF Capital Funds and the advisory clients of
TAG Associates and TAG Florida. We expect that certain conflicts will naturally be mitigated
by the different nature of acquisition targets for GF Funds and investments and those typically
pursued by advisory clients of TAG Associates and TAG Florida.
TAG and TAG Portfolio Management Group, LLC (the general partner or manager of the TAG
Fund domestic pools) provide investment advisory, management and other services to the TAG
Funds which are privately offered pooled investment vehicles, intended for investment by certain
investor suitability requirements defined by Section 2(a)(51) of the Investment Company Act of
1940, as amended (the “Company Act”) so as to comply with the exemptions under Section
3(c)(1) or 3(c)(7) of the Company Act. Thus, we are not independent from the TAG Funds, but
have a direct and beneficial interest in each TAG Fund. Further, our personnel have personally
invested in the TAG Funds and we are also responsible for soliciting new investors into certain
of the TAG Funds. These factors create an incentive to recommend TAG Funds (TAG does not
charge its clients additional fees). This is a conflict of interest, and consequently the investment
advice provided by us is conflicted. Please refer to the following section for more information of
the material financial interest we have in TAG Funds and subsequent conflicts of interest. When
appropriate and in the client’s best interest, TAG can recommend third-party investment adviser
firms to serve as investment managers to manage a portion of the client’s account. We do not
compensate investment managers for client referrals nor do investment managers compensate our
firm for client referrals. Client fees charged by investment managers are separate and distinct
from the fees we charge, as described in Item 5 of this brochure.
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Item 11 - Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
A client or prospective client may obtain a copy of our Code of Ethics (the “Code”) by
contacting David Basner or Jorge Gonzalez at 212-275-1500.
TAG Associates LLC (“we” or “us”) has adopted a Code of Ethics (the “Code”) for all
supervised persons of the firm discussing its high standard of business conduct and fiduciary
duty to its clients. The Code includes provisions relating to protecting the confidentiality of
client information, a prohibition on insider trading, a prohibition on rumor mongering,
restrictions on the acceptance of significant gifts and the reporting of certain gifts and business
entertainment items, and personal securities trading procedures, among other issues. All
supervised persons at TAG must acknowledge the terms of the Code of Ethics annually, or as
amended.
As a firm we impose no general prohibition on the security transactions of our associated persons
and employees other than those imposed by our insider trading policies and applicable securities
law and regulations. However, we do prohibit any TAG employees from investing in public
companies in which our clients maintain influential or controlling positions. Accordingly, it is
permissible for an individual member of our investment committee to invest personally in a fund
or place personal funds with an advisor that we are also recommending to our clients. Any such
investment or arrangement would be made at arms' length and on the same terms as are available
at the time to any other client investors. TAG employees that are members of the investment
committee or otherwise meet certain investor suitability requirements may also invest in the
TAG Funds described in Item 4.
The Code of Ethics is designed to assure that the personal securities transactions, activities and
interests of TAG employees will not interfere with (i) making decisions in the best interest of
our advisory clients and (ii) implementing such decisions while, at the same time, allowing
employees to invest for their own accounts. Under the Code certain classes of securities have
been designated as exempt transactions (e.g., mutual funds), based upon a determination that
these would not materially interfere with the best interest of our clients.
Nonetheless, because the Code of Ethics in some circumstances permits employees to invest in
the same securities as clients, there is a possibility that employees might benefit from market
activity by a client in a security also held by an employee. Investments by both clients and TAG
employees in a private placement, however, should not result in benefit to a TAG employee to the
disadvantage of our clients. The Code requires monthly monitoring of employee trades (other
than investments in mutual funds, ETFs, or when employees fully relinquish control of trading
activities in discretionary managed accounts) to reasonably prevent conflicts of interest between
TAG and its clients.
We do not effect any principal transactions for client accounts. “Principal transactions” are
generally defined as transactions where an adviser, acting as principal for its own account or the
account of an affiliated broker-dealer, buys from or sells any security to any advisory client.
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We will recommend TAG Funds to our wealth management and portfolio management clients.
We have a material financial interest when recommending TAG Funds. We address for this
conflict by comparing TAG Funds against other registered or non-registered pooled investment
vehicles and we will recommend other pooled investment vehicles when more appropriate for the
client. We will only recommend that a client invest a portion of such a client’s portfolio in TAG
Funds if we believe that it is in the client’s best interest. Under no circumstances will the Adviser
exercise any investment discretion with respect to whether to invest a client’s assets in the TAG
Funds.
Because our recommendation that clients invest in TAG Funds is an inherent conflict of interest
that cannot be completely overcome, we strongly encourage all clients to consult with legal
counsel, an accountant, a third-party investment adviser not affiliated with TAG, or any other
financial professional of the client’s choosing who is not affiliated with TAG for a “second
opinion” before investing in the TAG Funds.
If clients choose to invest in the TAG Funds, we will not charge “double-fees” meaning we will
only charge one fee against the assets invested in TAG Funds.
We permit our owners and employees to invest in the TAG Funds. Employees seeking to invest in
any private offering, including TAG Funds, must first be approved, by our Chief Compliance
Officer prior to any purchase or redemption in the private security.
Private investments like TAG Funds are often illiquid which means that the investments can be
difficult to trade and consequently limits an investor's ability to dispose of such investments in a
timely manner and at an advantageous price. Additionally, such investments will not register
pursuant to the Securities Act of 1933, and therefore investors must complete a subscription
agreement showing the investor is an "accredited" investor, and for certain TAG Funds a
“Qualified Purchaser” (as defined by applicable law, rules and regulations) and acknowledge that
he or she has read and understands the confidential Subscription Documents and is aware of the
various risk factors associated with such an investment in a TAG Fund.
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Item 12 - Brokerage Practices
Advisor Directed Brokerage
As a fiduciary, TAG endeavors to act in its clients' best interests. TAG recommends independent
brokers based on its analysis of their performance and how such performance compares to those
of other brokers. TAG receives no fee or economic inducement of any sort from such brokers
for making such a recommendation. Recommendations are limited to those brokers who have
been reviewed by TAG. Criteria such as custodial services, quality of customer experience,
research content, trade execution quality, and access to institutional-tier mutual funds are some
of the criteria used to evaluate brokers. Years of operation, management team, and employee
turnover are also important factors when determining fit and quality when making such
recommendations.
For clients who wish to establish a managed account or implement TAG’s portfolio management
advice through our Firm, we often recommend Charles Schwab & Company, Inc. (Charles
Schwab).
When clients sign an agreement with our Firm, they may choose to establish a brokerage account
with Charles Schwab if they do not already have one. Charles Schwab is a registered broker-
dealer, member SIPC, and will maintain custody of clients’ assets and provide execution of
securities transactions. TAG is independently owned and operated and not affiliated with
Charles Schwab, nor does the firm receive client referrals from Charles Schwab
Not all investment advisors recommend or require the use of a specific broker/dealer. Some
investment advisors allow clients to select the broker/dealer. For compliance and operational
efficiency purposes, we have decided to utilize the offerings of Schwab Advisor Services and
therefore strongly encourage all clients to open accounts through Charles Schwab when
participating in the firm’s Wealth Management and Portfolio Management Services.
On a periodic basis, we will review alternative custodians in the marketplace for comparison to
the currently used primary custodian. The aforementioned criteria will be used to evaluate
overall broker expertise, cost competitiveness and financial condition. No single criteria will
validate nor invalidate a custodian, but rather, all criteria taken together will be used in
evaluating the currently utilized custodian.
The decision to frequently recommend Charles Schwab is based on the access clients of TAG
receive through Schwab Advisor Services and the quality of customer care clients of TAG
experience through Schwab’s Institutional platform offering. TAG periodically reviews the
Charles Schwab Best Execution policy, along with corresponding explicit and implicit costs
associated with Schwab Advisor Services when comparing offerings of other brokerage
platforms.
Through the Schwab Advisor Services platform, TAG is provided with access to Charles
Schwab’s institutional trading, custody, research and access to mutual funds and other
investment services, which are typically not available to Charles Schwab retail investors. These
services generally are available to independent investment advisors on an unsolicited basis, at
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no charge to them so long as a total of at least: $10 million of firm clients' assets is maintained
in accounts at Schwab Advisor Services and is not otherwise contingent upon TAG committing
to Charles Schwab any specific amount of business (assets in custody or trading).
For TAG clients' accounts maintained in its custody, Charles Schwab does not charge separately
for custody. Charles Schwab is compensated by account holders through commissions or other
transaction-related fees for securities trades that are executed through Charles Schwab or that
settle into Charles Schwab accounts. The commission and/or transaction fees charged by
Charles Schwab may be higher than those charged by other broker/dealers. Charles Schwab
enables our Firm to obtain many mutual funds without transaction charges and other securities
at nominal transaction charges. By establishing the bulk of our client accounts at Charles
Schwab, TAG is in a better position to negotiate commission and transaction fees paid by clients.
Charles Schwab makes available to TAG other products and services that benefit TAG but may
not benefit each clients' account directly. Some of these products and services assist TAG in
collectively managing and administering clients' accounts. These include software and other
technology that provide access to client account data (such as trade confirmation and account
statements); facilitate trade execution (and allocation of aggregated trade orders for multiple
client accounts); provide research, pricing information and other market data; facilitate payment
of advisory fees from its clients' accounts; and assist with back-office functions; recordkeeping
and client reporting. Many of these services generally may be used to service all or a substantial
number of TAG accounts.
Schwab Advisor Services also makes available to TAG products intended to help TAG manage
and further develop its business enterprise. These services include consulting, publications and
conferences on practice management, information technology, business succession best
practices, regulatory compliance and marketing.
Aggregating Securities Transactions for Client Accounts; Client Directed Brokerage
TAG primarily serves as the investment portfolio manager for its clients and generally does not
directly or indirectly execute trades (see Item 4). However, TAG does from time to time execute
trades for its clients. If trades in the same security are to be executed contemporaneously for
two or more clients, the Managing Director placing the trades will frequently aggregate those
trades.
TAG permits clients to direct TAG as to the choice of broker(s) for transactions on their behalf.
Client-directed brokerage may result in TAG being unable to obtain the most favorable
execution of transactions for those clients. For example, client-directed brokerage may mean
such clients pay higher brokerage commissions because TAG is unable to aggregate orders with
those of other clients to reduce transaction costs and may mean that such clients receive less
favorable prices.
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Other Potential Conflicts
Due to legal and investment business considerations and as set forth in TAG’s Code of Ethics,
in managing any client account, TAG employees may not act on material nonpublic information
learned by them through these relationships or otherwise. Accordingly, TAG may suspend
effecting transactions for client accounts with respect to a security when it becomes aware of
material nonpublic information affecting such security.
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Item 13 - Review of Accounts
Client Performance Reviews
Client portfolio accounts are reviewed periodically by a Managing Director and/or other
qualified personnel in charge of a particular client’s account. Portfolio changes can result from
a change in a client’s personal needs, macro-economic changes, change in laws, availability of
new investment products, and superior or inferior performance by a recommended or available
investment manager or product.
A Managing Director is primarily responsible for the review process associated with his or her
clients' portfolio accounts. Some Managing Directors are part of TAG’s Investment Committee.
Investment Committee members are also primarily responsible for investment decisions related
to the TAG Funds described in Item 4.
Nature/Frequency of Reports
All clients receive monthly or quarterly brokerage reports from the account custodians.
TAG's Comprehensive Wealth Management clients receive periodic (generally, quarterly)
reports that may include balance sheets, income statements, cash flows and tax projections in
addition to portfolio reporting. In some cases, monthly reports are generated. In rare, and in
agreed upon situations, the above-named reports may be generated on a semi-annual or annual
basis.
TAG's Portfolio Management clients receive either monthly or quarterly reports reflecting
overall portfolio performance as well as performance of the individual investment managers.
Performance is reported in absolute dollar terms and in relative terms. That is, the portfolio and
its component investment managers are compared in relation to applicable benchmarks and
indexes and other like styled investment managers that form part of such client’s portfolio of
investments.
Clients are encouraged to always compare any reports or statements provided by us 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.
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Item 14 - Client Referrals and Other Compensation
We do not directly or indirectly compensate anyone who does not work for our company for
client referrals.
The only compensation received from advisory services is the fees charged for providing such
services as described in Item 5 – Fees and Compensation and Item 6 – Performance-Based Fees
and Side-By-Side Management. Please refer to Item 12 – Brokerage Practices to read about the
benefits, services and tools described therein. Other than what is customary and incidental, TAG
does not receive forms of compensation or economic benefits, in connection with providing
investment advice, beyond the details already provided in Item 5, Item 6 and Item 12.
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Item 15 - Custody
TAG maintains custody of client cash and/or securities in accounts of clients who have
authorized TAG to implement certain types of client transactions. TAG also maintains custody
for certain other accounts due to the fact that supervised persons act as trustees or other types of
fiduciaries for those accounts and as such have authority to withdraw assets or otherwise
disburse funds without the client’s specific consent. Under Securities and Exchange
Commission (“SEC”) rules custody is imputed to TAG.
TAG has retained Grant Thornton LLP to conduct an examination of client accounts in which
TAG has custody of client assets. As a result, Grant Thornton LLP files a Form ADV-E with
the Securities and Exchange Commission (“SEC”) as part of TAG’s filing with the SEC.
Additional information can be found at www.adviserinfo.sec.gov.
For accounts in which TAG is deemed to have custody, we have established procedures to ensure
all client funds and securities are held at 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 manner in which the funds or securities are maintained. Clients will
receive at least quarterly statements from the broker dealer, bank or other qualified custodian
that holds and maintains their investment assets. TAG urges clients t o carefully review
such statements and compare such official custodial records to the account statements that TAG
may provide to them. TAG’s statements may vary from the custodial statements based on
accounting procedures, reporting dates or valuation methodologies of certain securities. When
clients have questions about their account statements, they should contact TAG or the qualified
custodian preparing the statement.
With respect to the TAG Funds, compliance with the custody rule may be satisfied under so-
called “audit exception” to the custody rule by: (i) having each TAG Fund audited at least
annually by an independent registered public accounting firm which is registered with the public
company accounting oversight board; and (ii) distributing audited financial statements prepared
in accordance with GAAP to all investors within 180 days of the end of its fiscal year.
Accordingly, each TAG Fund will generally distribute the audited financial statements of such
TAG Fund within 180 days of the end of the fiscal year to its investors.
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Item 16 - Investment Discretion
As detailed in Item 4, TAG provides overall portfolio management advice to our clients and does
not generally exercise discretion over client brokerage accounts. In some instances, our clients
have given us discretion over their brokerage accounts. Investment advice is provided pursuant to
a Portfolio Advisory Services Agreement between the Client and TAG. With respect to the clients
for which TAG has discretion over their accounts, the clients grant TAG the authority to enter into
agreements, including agreements with brokers, and take all steps to fully manage the Client’s
assets in accordance with the Client’s investment strategy.
When providing portfolio management services, TAG generally maintains trading authorization
over your Account and typically provides management services on a non- discretionary basis. By
managing accounts on a non-discretionary basis, we are 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 or dollar amount
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 we are not
able to reach you or you 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.
If you grant discretionary trading authority, we will have the authority to determine the type of
securities and the amount of securities that can be bought or sold for your portfolio without
obtaining your consent for each transaction.
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 TAG so long as the limitations are specifically set forth or included as an attachment to
the client agreement.
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Item 17 - Voting Client Securities
With the exception of those securities held by the TAG Funds that TAG manages, as detailed in
Item 4, TAG does not exercise voting authority over its clients’ proxies. Clients retain the
responsibility for receiving and voting proxies for any and all securities maintained in their
portfolios. Occasionally, TAG may provide advice to clients regarding the voting of proxies
related to private placement investments (e.g., hedge funds) made directly by the client.
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.
While alternative investments made by the TAG Funds are not typically the subject of proxies,
there could be certain circumstances where we, having discretionary authority over the accounts
of the TAG Funds, may be asked to vote the securities of such Funds on restructuring or other
corporate matters. We will ensure that a record of each securities position held by each TAG Fund
is maintained and, where any such vote is to occur, we will ensure that we receive all relevant
information, disclosure materials and such proxies or consents as are necessary for us to be able to
cast votes in a timely manner.
We will also determine whether there is, or appears to be, a material conflict of interest that could
influence the voting decision in a manner that would be adverse to the interests of a TAG Fund. If
we determine that there is no material conflict of interest, then we will make the voting
determination and take the required voting action. If we determine that, due to a conflict of interest,
we are not capable of making an independent determination as to the voting decision, we will
appoint an independent third party to make the applicable voting decision.
A TAG affiliate serves as general partner of each TAG Fund. As a result, each TAG Fund is aware
of how we voted with respect to its securities.
We will provide a copy of our policies and procedures concerning the voting of client securities to
clients upon request. Requests may be made to Jorge Gonzalez at 212-275-1500.
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Item 18 - Financial Information
TAG does not require or solicit prepayment of more than $1,200 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, TAG has not been the subject of a
bankruptcy petition at any time.
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