Overview
- Headquarters
- Saratoga Springs, NY
- Total Firm Assets
- $272 million
- Average High-Net-Worth Client Portfolio Size
- $2.5 million
Fee Structure
Primary Fee Schedule (TWS ADV2A FIRM BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $250,000 | 1.50% |
| $250,001 | $500,000 | 1.25% |
| $500,001 | $1,000,000 | 1.05% |
| $1,000,001 | $2,000,000 | 0.85% |
| $2,000,001 | $5,000,000 | 0.65% |
| $5,000,001 | and above | 0.55% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $12,125 | 1.21% |
| $5 million | $40,125 | 0.80% |
| $10 million | $67,625 | 0.68% |
| $50 million | $287,625 | 0.58% |
| $100 million | $562,625 | 0.56% |
Clients
- High-Net-Worth Share of Firm Assets
- 63.73%
- Number of High-Net-Worth Clients
- 70
- Total Client Accounts
- 744
- Discretionary Accounts
- 744
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection, Educational Seminars
Regulatory Filings
- SEC CRD Number
- 340266
Primary Brochure: TWS ADV2A FIRM BROCHURE (2026-06-05)
View Document Text
FORM ADV PART 2A: FIRM BROCHURE
FORM ADV PART 2A: FIRM BROCHURE
110 Henry Street, Saratoga Springs, NY 12866
(518) 583-4800
www.tailoredwealthsolutions.com
Date of Disclosure Brochure: June 5, 2026
This disclosure brochure provides information about the qualifications and business practices Tailored
Wealth Solutions, LLC (“TWS”) (also referred to as we and us throughout this disclosure brochure). If you
have any questions about the contents of this brochure, please contact us at (518) 583-4800 or
mike@tailoredwealthsolutions.com. The information in this disclosure brochure has not been approved or
verified by the United States Securities and Exchange Commission or by any state securities authority.
Additional information about Tailored Wealth Solutions is also available on the Internet at
www.adviserinfo.sec.gov. You can view our firm’s information on this website by searching for Tailored
Wealth Solutions or our firm’s CRD number 340266.
*Registration as an investment adviser does not imply a certain level of skill or training.
SIMPLIFY. ORGANIZE. MAXIMIZE.
ITEM 2 - MATERIAL CHANGES
ITEM 2 - MATERIAL CHANGES
We will ensure that you receive a summary of any material changes to this and subsequent disclosure
brochures within 120 days after our firm’s fiscal year ends. Our firm’s fiscal year ends on December 31, so
you will receive the summary of material changes no later than April 30 each year. At that time, we will
also offer or provide a copy of the most current disclosure brochure. We may also provide other
ongoing disclosure information about material changes as necessary.
Since our initial filing, we have made changes to Item 5 – Fees and Compensation of this brochure to
update our billing calculation method, frequency, and fee schedule.
ITEM 2 - MATERIAL CHANGES
ITEM 3 - TABLE OF CONTENTS
ITEM 3 - TABLE OF CONTENTS
Item 1 – Cover Page...........................................................................................................................................................
Item 2 – Material Changes...........................................................................................................................................
Item 3 – Table of Contents...........................................................................................................................................
Item 4 – Advisory Business...........................................................................................................................................
Introduction....................................................................................................................................................................
Description of Advisory Services......................................................................................................................
Retirement Plan Rollover Recommendations........................................................................................
Limits Advice to Certain Types of Investments.....................................................................................
Tailor Advisory Services to Individual Needs of Clients...................................................................
Client Assets Managed by Tailored Wealth Solutions.....................................................................
Item 5 – Fees and Compensation..........................................................................................................................
Item 6 – Performance-Based Fees and Side-By-Side Management...........................................
Item 7 – Types of Clients................................................................................................................................................
Minimum Investment Amounts Required.................................................................................................
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss.........................................
Methods of Analysis..................................................................................................................................................
Investment Strategies.............................................................................................................................................
Risk of Loss......................................................................................................................................................................
Item 9 – Disciplinary Information............................................................................................................................
Item 10 – Other Financial Industry Activities and Affiliations................................................................
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading..........
Code of Ethics Summary......................................................................................................................................
Affiliate and Employee Personal Securities Transactions Disclosure....................................
Item 12 – Brokerage Practices....................................................................................................................................
Block Trading Policy..................................................................................................................................................
Item 13 - Review Of Accounts.....................................................................................................................................
Account Reviews and Reviewers.....................................................................................................................
Statements and Reports. .....................................................................................................................................
Item 14 – Client Referrals and Other Compensation..................................................................................
Item 15 – Custody................................................................................................................................................................
Item 16 – Investment Discretion. ..............................................................................................................................
Item 17 – Voting Client Securities.............................................................................................................................
Item 18 – Financial Information.................................................................................................................................
ITEM 3 - TABLE OF CONTENTS1234458910101115151516161718222326262627292929303031313232
ITEM 4 - ADVISORY BUSINESS
ITEM 4 - ADVISORY BUSINESS
Tailored Wealth Solutions, LLC is a New York limited liability company founded in August 2020, with its
principal place of business in New York. Michael R. Testa, CRPS® is the principal owner of Tailored Wealth
Solutions and has focused his practice on customized financial planning & wealth management.
Mr. Testa is the Founder and primary control person of Tailored Wealth Solutions. Full details of the
education and business background of Mr. Testa are provided in his Form ADV Part 2B Brochure
Supplement.
Tailored Wealth Solutions filed its initial application with the SEC to become registered as an
investment adviser in January 2026.
Michael R. Testa, CRPS®
As Founder and CEO of Tailored Wealth Solutions, Michael has spent more
than 20 years helping individuals, families, and business owners simplify
complex decisions, organize their financial lives, and maximize what matters
most: long-term wealth, security, and peace of mind.
His work is grounded in retirement income planning, tax-aware strategy, and
thoughtful planning for business owners. Michael holds FINRA Series 7, 66, and
31 licenses, along with Life, Accident, and Health Insurance licenses, and is a
Chartered Retirement Plans Specialist™ (CRPS®). These credentials support a
planning-first approach that is both comprehensive and practical.
*Chartered Retirement Plans Specialist™ and CRPS® are registered service marks of the College for Financial Planning.
Introduction
The investment advisory services of Tailored Wealth Solutions are provided to you through an appropriately
licensed and qualified individual who is an investment adviser representative of Tailored Wealth Solutions
(referred to as your investment adviser representative “IAR” or “Advisor” throughout this brochure). The firm
focuses on offering individualized wealth management services which may include but are not limited to
asset management, investment advice, financial planning, tax planning or estate planning.
ITEM 4 - ADVISORY BUSINESS
Description of Advisory Services
The following are descriptions of the primary advisory services of Tailored Wealth Solutions. Please
understand that a written agreement, which details the exact terms of the service, must be signed by you
and Tailored Wealth Solutions before we can provide you with the services described below.
Asset Management Services
We offer discretionary asset management services. Our investment advice is tailored to meet our clients'
needs and investment objectives. If you retain our firm for asset management services, we will meet with
you to determine your investment objectives, risk tolerance, and other relevant information at the beginning
of our advisory relationship. Based on this information, we develop a personalized investment strategy,
which may include a written investment policy statement or an asset allocation plan. We then construct
and manage the portfolio to align with the agreed-upon targets and investment approach. We provide
continuous and customized investment advice based on each client’s unique financial situation, goals, and
preferences. We may also invest your assets according to one or more model portfolios developed by an
unaffiliated investment adviser firm. Once we select a model portfolio, we will monitor your portfolio's
performance on an ongoing basis and will adjust the portfolio as required by changes in market conditions
and in your financial circumstances.
If you participate in our discretionary asset management services, we require you to grant our firm
discretionary authority to manage your account. Discretionary authorization will allow us to determine the
specific securities, and the amount of securities, to be purchased or sold for your account and the
commissions to be paid to brokerage firms without your approval prior to each transaction. We will also
have discretion to place all or a portion of your assets with sub-advisors we select.
Discretionary authority is typically granted by the Investment Advisory Agreement you sign with our firm
and the appropriate trading authorization forms. In managing portfolios, we consider each client’s stated
objectives, such as capital appreciation, income, growth, or a combination thereof—as well as relevant tax
considerations. Clients may impose reasonable restrictions on investing in specific securities, types of
securities, or industry sectors. You may limit our discretionary authority (for example, limiting the types of
securities that can be purchased or sold for your account) by providing our firm with your restrictions and
guidelines in writing.
Asset Management Services: Sub-Advisors/Third Party Managers (“TPAs”)
As part of our investment advisory services, we often use one or more sub-advisors or third-party money
manager(s) (“Other Managers”) to manage a portion of your account on a discretionary basis. Our firm
may utilize the services of various Other Managers for the management of client accounts, allocating client
assets among such managers as appropriate. In such cases, Other Managers will be responsible for
continuously monitoring client accounts and making trades in client accounts when necessary. While the
chosen Other Managers will provide advice on specific securities and/or other investments in connection
with this service, our firm has discretionary authority to hire and fire such Other Managers and reallocate
assets among them as deemed appropriate. We will assist you with identifying your risk tolerance and
investment objectives, and, in turn, retain Other Managers in relation to your stated investment objectives
and risk tolerance. The Other Managers, if utilized, will charge an additional fee as compensation for their
direct management of your account. This fee will not exceed the maximum fee disclosed in your Investment
Advisory Agreement with our firm.
ITEM 4 - ADVISORY BUSINESS
Wrap Fee Programs
A wrap fee program is a program under which the client pays a single fee that covers both receipt of
investment advice and the execution of securities transactions. TWS does not sponsor a wrap fee program,
however we may utilize sub-advisors as described above which sponsor wrap programs. If you participate
in a third-party wrap program, it will be on a discretionary basis. The strategies implemented are based on
clients' individual investment objectives.
When using third-party managers or sub-advisors you may be required to complete additional paperwork
for those managers. Additionally, these accounts may participate in wrap programs sponsored by the
chosen managers. Please review all disclosures provided by or about third-party managers or sub-advisors
to ensure you understand what costs their wrap programs cover.
Financial Planning Services
Our firm also provides financial planning services. As part of our advisory services, Tailored Wealth Solutions
(TWS) provides comprehensive financial planning tailored to each client’s unique circumstances. This
process involves an in-depth evaluation of your current and future financial position, considering known
variables to project future cash flows, asset values, and withdrawal strategies. We take a holistic approach
and examine how various components of your financial life affect one another. Clients who engage in this
service will receive a written or electronic financial plan outlining actionable recommendations designed to
help meet their stated goals. Financial planning services can be a one-time engagement or an ongoing
service based on individual client needs. The Firm may charge additional or separate fees for planning
services, which we will detail in the Financial Planning agreement you sign with us. Regardless of the nature
of the service, the implementation of all recommendations will be at the client's discretion.
A financial plan will address one or more of the following areas:
Financial Position: Understanding of a client's current financial situation.
Investment Planning: Determining the most suitable way to structure investments to meet financial
goals, and determine the appropriate account type (e.g., joint tenants, IRA, Roth IRA, etc.)
Personal Tax Planning: Evaluating the current tax situation to help minimize a client's taxes and find more
profitable ways to use the extra income generated.
Retirement Planning: Assessing retirement needs to help a client determine how much to accumulate,
as well as distribution strategies designed to create a source of income during retirement years.
Insurance Planning and Risk Management: Evaluating the client's insurance needs and reviewing
insurance needs, existing policies, and goals. We analyze potential financial threats from unexpected
events such as premature death, disability, or long-term care needs, and offer recommendations for
mitigating those risks through insurance or other strategies
Estate Planning: Reviewing the client's cash needs at death, income needs of surviving dependents and
estate planning goals.
Charitable Planning: Providing strategic charitable giving plans for clients and researching and
evaluating charitable entities and private foundations.
Mortgage/Debt Analysis: Analyzing client's current mortgage debt, home equity, and financing
alternatives.
Review of Employee Benefit Plans: Reviewing the client's investment options, allocation models and
historical performance of client assets held through employee benefit plans.
College Savings: We project education funding needs and recommend savings strategies, while also
helping clients assess financial aid considerations and gifting strategies for children or grandchildren.
ITEM 4 - ADVISORY BUSINESS
We gather information at an initial meeting which includes interviews and a review of documents provided
by the client. Information gathered includes the client's current financial status, future goals, investment
objectives, risk tolerance and family circumstances.
Typical financial planning services include one or more of each of the service components. A financial plan
could require the services of a specialist such as an insurance specialist, attorney or tax accountant. We will
recommend third-party service providers if we feel it is appropriate and in your best interest, but you are
under no obligation to use any service provider recommended by us. Likewise, you are under no obligation
to act on our financial planning recommendations. We do not receive referral or other fees from third-party
service providers.
Financial plans are based on the client's financial situation at the time we present the financial plan to the
client, and on the information provided to us. The client must promptly notify us if his/her financial situation,
goals, objectives or needs change. Certain assumptions are made with respect to interest rates, inflation
rates, and use of past trends and performance of the market and economy. Past performance is in no way
an indication of future performance. We do not offer any guarantees or promises that a client's financial
goals will be met.
Retirement Planning
We provide investment advice and financial planning for your retirement accounts and retirement plans.
When we provide investment advice to you regarding your retirement plan account or individual retirement
account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act
and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way
we make money creates some conflicts with your interests, so we operate under a special rule that requires
us to act in your best interest and not put our interest ahead of yours.
Under this special rule’s provisions, we must:
Meet a professional standard of care when making investment recommendations (give prudent
advice);
Never put our financial interests ahead of yours when making recommendations (give loyal advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that we give advice that is in your best interest;
Charge no more than is reasonable for our services; and
Give you basic information about conflicts of interest.
Retirement Plan Rollover Recommendations
To the extent we recommend you roll over your account from a current retirement plan to an individual
retirement account (“Rollover IRA”), managed by Tailored Wealth Solutions please know that Tailored
Wealth Solutions and our investment adviser representatives have a conflict of interest.
We can earn increased investment advisory fees by recommending that you roll over your account at the
retirement plan to a Rollover IRA managed by Tailored Wealth Solutions. We will earn fewer investment
advisory fees if you do not roll over the funds in the retirement plan to a Rollover IRA managed by Tailored
Wealth Solutions.
Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds
from a retirement plan to a Rollover IRA which is a conflict of interest because our recommendation that
ITEM 4 - ADVISORY BUSINESS
you open an IRA account to be managed by our firm can be based on our economic incentive and not
based exclusively on whether or not moving the IRA to our management program is in your overall best
interest.
We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard
whereby our investment adviser representatives will (i) provide investment advice to a retirement plan
participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status
described below, (ii) not recommend investments which result in Tailored Wealth Solutions receiving
unreasonable compensation related to the rollover of funds from the retirement plan to a Rollover IRA, and
(iii) fully disclose compensation received by Tailored Wealth Solutions and our supervised persons and any
material conflicts of interest related to recommending the rollover of funds from the retirement plan to a
Rollover IRA and refrain from making any materially misleading statements regarding such rollover.
To the extent we provide you investment advice as a participant in a retirement plan regarding whether to
maintain investments and/or proceeds in the retirement plan, roll over such investment/proceeds from the
retirement plan to a Rollover IRA or make a distribution from the retirement plan, Tailored Wealth Solutions
hereby acknowledges our fiduciary obligations to you with regard to our investment advice about whether
to maintain, roll over or distribute proceeds from the retirement plan, and as such a fiduciary with respect to
its investment advice to you about whether to maintain, roll over or distribute proceeds from the retirement
plan.
Our investment advisor representatives shall act with the care, skill, prudence, and diligence under the
circumstances then prevailing that a prudent person acting in a like capacity and familiar with such
matters would use in the conduct of an enterprise of a like character and with like aims, based on the
investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the
financial or other interests of Tailored Wealth Solutions or our affiliated personnel.
Newsletters, Online Content, and Seminars
Tailored Wealth Solutions occasionally prepares general, educational and informational newsletters, videos
or social media posts. This content is always offered on an impersonal basis and does not focus on the
needs of a specific individual. This content is provided to clients and prospective clients free of charge.
We may host occasional Seminars for clients or prospective clients. Seminar topics focus on financial
planning topics but can also include other general financial topics. Seminars are always offered on an
impersonal basis and do not focus on the individual needs of participants. Seminars are offered to clients
and prospects free of charge.
ITEM 4 - ADVISORY BUSINESS
Limits Advice to Certain Types of Investments
Tailored Wealth Solutions can provide investment advice on the following types of investments:
Mutual Funds
Exchange Traded Funds (ETFs)
Exchange-listed Securities
Securities Traded Over the Counter
Foreign Issues
Warrants
Corporate Debt Securities
Commercial Paper
Certificates of Deposit
Municipal Securities
Variable Annuities
Variable Life Insurance
US Government Securities
Interests in Partnerships Investing in Real Estate
Interests in Partnerships Investing in Oil and Gas Interests
Securities Properly Exempted from Registration
Hedge Funds
Non-Traded Real Estate Investment Trusts (REITs)
Business Development Companies
Private Placements or Equities
Structured Notes
Cryptocurrency and Crypto Related Securities
Although we generally provide advice only on the products previously listed, we reserve the right to offer
advice on any investment product that can be suitable for each client’s specific circumstances, needs,
goals and objectives.
It is not our typical investment strategy to attempt to time the market, but we can increase cash holdings
modestly as deemed appropriate based on your risk tolerance and our expectations of market behavior.
We can modify our investment strategy to accommodate special situations such as low basis stock, stock
options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please
refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.)
ITEM 4 - ADVISORY BUSINESS
Tailor Advisory Services to Individual Needs of Clients
Tailored Wealth Solutions advisory services are always provided based on your individual needs. This
means, for example, that when we provide asset management services, you are given the ability to impose
restrictions on the Accounts we manage for you, including specific investment selections and sectors. We
work with you on a one-on-one basis through interviews and questionnaires to determine your investment
objectives and suitability information. Our recommendations are crafted with an individualized, detailed
financial plan which takes into consideration your overall investment knowledge and goals.
We will not enter into an investment adviser relationship with a prospective client whose investment
objectives may be considered incompatible with our investment philosophy or strategies or where the
prospective client seeks to impose unduly restrictive investment guidelines.
When managing client Accounts through our firm’s Asset Management Services program, we can manage
a client’s Account in accordance with one or more investment models. When client Accounts are managed
using models, investment selections are based on the underlying model, and generally we do not develop
customized (or individualized) portfolio holdings for every client. However, the determination to use a
particular model or models is always based on each client’s individual investment goals, objectives and
mandates. We may recommend a mixture of investment models and individualized trade strategies or
create an individualized portfolio based on what we believe to be in our clients best interests.
Client Assets Managed by Tailored Wealth Solutions
As of June 5, 2026, Tailored Wealth Solutions had Discretionary Assets Under Management of $271,777,434.
ITEM 4 - ADVISORY BUSINESS
ITEM 5 - FEES AND COMPENSATION
ITEM 5 - FEES AND COMPENSATION
In addition to the information provided in Item 4 – Advisory Business, this section provides additional details
regarding our firm’s services along with descriptions of each service’s fees and compensation
arrangements. It should be noted that lower fees for comparable service can be available from other
sources. The exact fees and other terms will be outlined in the agreement between you and Tailored Wealth
Solutions.
Fees for Asset Management Services
The total annual advisory fee due to us for Asset Management Services (“Advisory Fee”) is negotiable at the
sole discretion of our firm and will be outlined in the Investment Advisory Agreement signed by the client
and our firm. The maximum annual Advisory Fee charged for these services will be up to 1.5% of the total
assets under management, and will not include all fees payable to sub-advisers or third party investment
advisers (“TPAs”) we engage on your behalf.
Our standard annual fee schedule for Asset Management follows a blended tiered fee schedule which is:
Asset Management Fee
Asset Level
First $0 – $250,000
1.50%
Next $250,001 – $500,000
1.25%
Next $500,001 – $1,000,000
1.05%
Next $1,000,001 – $2,000,000
0.85%
Next $2,000,001 – $5,000,000
0.65%
Next $5,000,001+
0.55%
This is the current fee schedule for newly onboarded clients of the firm who have entered into an Advisory
Agreement with this schedule in place. Previous advisory relationships are subject to different fee schedules
and negotiated fee arrangements in accordance with the fee schedule and Advisory Agreement in place at
the time they onboarded. The fee schedule does not imply that fees are the same for everyone, including
legacy clients.
Asset Management Fees are typically billed monthly in advance based on each account's prior month end
balance.
The final effective fee rate is lower than the highest percentage in the schedule when blended tiers of asset
levels are considered.
ITEM 5 - FEES AND COMPENSATION
Fees for Asset Management: Retirement Plans
Fees for Asset Management of retirement plans are typically billed monthly in advance based on the
average daily balance during the prior calendar quarter. Our standard fee schedule for asset management
of retirement plans is a flat tiered fee schedule which is:
Asset Management Fee
Asset Level
0 – 500K
1.25%
500K - 3 Million
1.00%
3 - 5 Million
0.75%
5 - 10 Million
0.50%
10 Million +
0.25%
For all asset management fees, the first monthly fee shall be prorated based on the portion of such time
period remaining when you sign your agreement with us. When services begin the prorated fee is
calculated and added to the next billing cycle. Advisory Fees are negotiable and will be deducted from
client account(s) by the qualified custodian based on instruction from us and/or a sub-adviser. In rare
cases, our firm will agree to direct bill clients. The fee rate for your accounts will always be reflected in your
Investment Advisory Agreement with us and the amounts charged will be on your account statements
provided by the qualified custodian holding your account(s).
Fees for Asset Management Services through Third Party Advisors (“TPAs”)
Our above fee schedule includes our standard fees for accounts and does not include fees for accounts
managed by third party advisors/sub-advisors we select. The Advisory Fee payable to the sub-adviser or
TPA is established and payable in accordance with the brochure provided by each TPA to whom you are
recommended. These fees for sub-advisors or TPAs range from 0.02% - 0.60% depending on the manager
and strategy selected, and are not negotiable. Furthermore, different models made available through TPAs
also charge different fees; accordingly, our net compensation also differs depending upon the model
selected. Investment Advisory fees incurred by Client will increase when the Client or TWS elects to use a
TPA.
Because our clients do not typically pay transaction fees for the investments we recommend, it would not
benefit our clients for us to determine whether asset-based or transaction-based pricing is more expensive.
Rather, it would only benefit our firm to pay lower transaction fees. However, in order to simplify our business
model and eliminate the need for continuous analysis of which transaction pricing models are most
profitable to our firm, we have adopted a policy of using only asset-based pricing, which carries a platform
fee that is higher than what we would pay for transaction-based pricing. In the absence of this policy, in
some situations we would have an incentive to minimize our transaction costs by placing assets in
transaction-based accounts and to reduce trading in those accounts. Our policy to use asset-based
pricing exclusively eliminates any incentive to recommend those types of accounts to our clients, or to
manage the accounts in that manner.
ITEM 5 - FEES AND COMPENSATION
Our receipt of an asset-based fee presents a conflict of interest. This is because the more assets there are
in the client’s account, the more the client will pay in fees. Therefore, we have an incentive to encourage
clients to increase the assets in their accounts. We address this conflict of interest by ensuring any such
recommendations are in the client’s best interest.
Financial Planning & Estate Design Fees
We typically charge flat fee amounts for Financial Planning services. Our fees will generally range between
$3,000 - $25,000 depending on planning needs and complexity.
Fees are charged as one time or ongoing depending on the terms of your Financial Planning Agreement
with us.
If you terminate the financial planning and consulting services after entering into an agreement with us and
the IAR did not waive your fees, you will be responsible for immediate payment of any financial planning
and consulting services performed by the firm prior to our receipt of your notice of termination.
We may on occasion agree to do specialized projects for a Client at an hourly rate of no more than $500
per hour which will be memorialized in your Financial Planning Agreement with us. You will be invoiced and
provided with a reconciliation for hours billed if you engage in this type of agreement.
Other Fee Terms
You should notify Tailored Wealth Solutions within ten (10) days of receipt of an invoice if you have questions
about or dispute any billing entry.
All fees paid to TWS for advisory services are separate and distinct from the fees and expenses charged by
mutual funds to their shareholders. These fees and expenses are described in each mutual fund’s
prospectus. These fees will generally include a management fee, other fund expenses, and a possible
distribution fee. If the fund also imposes sales charges, you may pay an initial or deferred sales charge.
Clients incur certain charges imposed by custodians, brokers, and other third parties such as administrative
custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, and electronic fund fees, and
other fees and taxes on brokerage accounts and securities transactions. Please refer to Item 12 (Brokerage
Practices) in this Brochure for additional information.
All fees paid to TWS for services are separate and distinct from the commissions, fees, and expenses
charged by insurance companies associated with any disability insurance, life insurance, and annuities
subsequently acquired by you. If you sell or liquidate certain existing securities positions to acquire any
insurance or annuity, you may also pay commissions, fees, and expenses charged by the insurance
company for subsequently-acquired insurance and/or annuities in addition to the financial planning and
consulting fees paid to TWS for Advisory Services. Please see Item 10 of this brochure for more information
about our outside professional activities.
To the extent Tailored Wealth Solutions engages an outside professional (i.e., attorney, independent
investment adviser or Accountant) while providing advisory services to you, Tailored Wealth Solutions will be
responsible for the payment of the fees for the services of such an outside professional, and you will not be
required to reimburse Tailored Wealth Solutions for such payments.
ITEM 5 - FEES AND COMPENSATION
To the extent that you personally engage such an outside professional, you will be responsible for the
payment of the fees for the services of such an outside professional, and Tailored Wealth Solutions will not
be required to reimburse Client for such payments. Fees for the services of an outside professional (i.e.,
attorney, independent investment adviser or Accountant) will be in addition to and separate from the fees
charged by Tailored Wealth Solutions, and you will be responsible for the payment of the fees for the
services of such an outside professional.In no event will the services of an outside professional be engaged
without your express approval. Please see Item 10 of this brochure for more information about our outside
professional activities.
ITEM 5 - FEES AND COMPENSATION
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-
BY-SIDE MANAGEMENT
BY-SIDE MANAGEMENT
Performance-based fees are defined as fees based on a share of capital gains on or capital appreciation
of the assets held in a client’s Account. Item 6 is not applicable to this Disclosure Brochure because we do
not charge or accept performance-based fees.
ITEM 7 – TYPES OF CLIENTS
ITEM 7 – TYPES OF CLIENTS
Tailored Wealth Solutions generally provides investment advice to the following types of clients:
Individuals
High net worth individuals
Businesses
Retirement Plans
You are required to execute a written agreement with Tailored Wealth Solutions specifying the particular
advisory services in order to establish a client arrangement with Tailored Wealth Solutions.
Minimum Investment Amounts Required
Tailored Wealth Solutions does not require a minimum account value in order to open an Account.
Sub-advisors we recommend may have minimum account and minimum fee requirements in order to
participate in their programs. The sub-adviser will disclose its minimum account size and fees in its Form
ADV Part 2A Disclosure Brochure.
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT | ITEM 7 - TYPES OF CLIENTS
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT
STRATEGIES AND RISK OF LOSS
STRATEGIES AND RISK OF LOSS
Methods of Analysis
Tailored Wealth Solutions uses the following methods of analysis in formulating investment advice:
Charting - This is a set of techniques used in technical analysis in which charts are used to plot
price movements, volume, settlement prices, open interest, and other indicators, in order to
anticipate future price movements. Users of these techniques, called chartists, believe that past
trends in these indicators can be used to extrapolate future trends.
Charting is likely the most subjective analysis of all investment methods since it relies on proper
interpretation of chart patterns. The risk of reliance upon chart patterns is that the next day's data
can always negate the conclusions reached from prior days' patterns. Also, reliance upon chart
patterns bears the risk of a certain pattern being negated by a larger, more encompassing
pattern that has not shown itself yet.
Fundamental – This is a method of evaluating a security by attempting to measure its intrinsic
value by examining related economic, financial and other qualitative and quantitative factors.
Fundamental analysts attempt to study everything that can affect the security's value, including
macroeconomic factors (like the overall economy and industry conditions) and individually
specific factors (like the financial condition and management of a company). The end goal of
performing fundamental analysis is to produce a value that an investor can compare with the
security's current price in hopes of figuring out what sort of position to take with that security
(underpriced = buy, overpriced = sell or short). Fundamental analysis is considered to be the
opposite of technical analysis.Fundamental analysis is about using real data to evaluate a
security's value. Although most analysts use fundamental analysis to value stocks, this method of
valuation can be used for just about any type of security.
The risk associated with fundamental analysis is that it is somewhat subjective. While a
quantitative approach is possible, fundamental analysis usually entails a qualitative assessment
of how market forces interact with one another in their impact on the investment in question. It is
possible for those market forces to point in different directions, thus necessitating an
interpretation of which forces will be dominant. This interpretation may be wrong and could
therefore lead to an unfavorable investment decision.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Technical – This is a method of evaluating securities by analyzing statistics generated by market
activity, such as past prices and volume. Technical analysts do not attempt to measure a
security's intrinsic value, but instead use charts and other tools to identify patterns that can
suggest future activity. Technical analysts believe that the historical performance of stocks and
markets are indications of future performance.
Technical analysis is even more subjective than fundamental analysis in that it relies on proper
interpretation of a given security's price and trading volume data. A decision might be made
based on a historical move in a certain direction that was accompanied by heavy volume;
however, that heavy volume may only be heavy relative to past volume for the security in
question, but not compared to the future trading volume. Therefore, there is the risk of a trading
decision being made incorrectly, since future trading volume is unknown. Technical analysis is
also done through observation of various market sentiment readings, many of which are
quantitative. Market sentiment gauges the relative degree of bullishness and bearishness in a
given security, and a contrarian investor utilizes such sentiment advantageously. When most
traders are bullish, then there are very few traders left in a position to buy the security in question,
so it becomes advantageous to sell it ahead of the crowd. When most traders are bearish, then
there are very few traders left in a position to sell the security in question, so it becomes
advantageous to buy it ahead of the crowd. The risk in utilization of such sentiment technical
measures is that a very bullish reading can always become more bullish, resulting in lost
opportunity if the money manager chooses to act upon the bullish signal by selling out of a
position. The reverse is also true in that a bearish reading of sentiment can always become more
bearish, which may result in a premature purchase of a security.
Investment Strategies
Tailored Wealth Solutions may employ the following investment strategies when managing client assets
and/or providing investment advice:
Long term purchases. Investments held at least a year.
Short term purchases. Investments sold within a year.
Value Investing. Value Investing can be described as a strategy of selecting stocks that trade for
less than their intrinsic values. Value investors typically seek stocks of companies that they
believe the market has undervalued. They believe the market overreacts to good and bad news,
resulting in stock price movements that do not correspond with the company's long-term
fundamentals. The result is an opportunity for value investors to profit by buying when the price is
deflated. Often, value investors select stocks with lower-than-average price-to-book or price-to-
earnings ratios and/or high dividend yields. The risks associated with value-investing include
incorrectly analyzing and overestimating the intrinsic value of a business, concentration risk,
under performance relative to major benchmarks, macro-economic risks, investing in value traps
i.e., businesses that remain perpetually undervalued, and lost purchasing power on cash holdings
in the case of inflation.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Tactical asset allocation. Allows for a range of percentages in each asset class (such as Stocks =
40-50%). The ranges establish minimum and maximum acceptable percentages that permit the
investor to take advantage of market conditions within these parameters. Thus, a minor form of
market timing is possible, since the investor can move to the higher end of the range when stocks
are expected to do better and to the lower end when the economic outlook is bleak.
Strategic asset allocation. Calls for setting target allocations and then periodically rebalancing
the portfolio back to those targets as investment returns skew the original asset allocation
percentages. The concept is akin to a “buy and hold” strategy, rather than an active trading
approach. Of course, the strategic asset allocation targets may change over time as the client’s
goals and needs change and as the time horizon for major events such as retirement and college
funding grow shorter.
Investment Model Strategies. Tailored Wealth Solutions has created proprietary Model Portfolios.
Based on the information you provide us, we consider multiple time horizons (long, medium and
short-term) when determining investment strategies. Depending on our clients’ needs, we may
recommend one or several of our investment management models.
In the development and management of our Model Portfolios, Tailored Wealth Solutions uses
industry standard techniques that include technical analysis, fundamental analysis and charting.
We may engage various types of execution tactics such as long term and short-term buys and
value investing as well as asset allocation strategies to achieve the Model Portfolios’ objectives.
Each model engages in its own type of techniques, execution tactics and use of research tools to
enhance the ability to manage its assets effectively to its stated philosophy. Tailored Wealth
Solutions actively manages each model’s investment objective, driven by its investment
philosophy and style.
Primarily Recommend One Type of Security
We do not primarily recommend one type of security to clients. Instead, we recommend any product that
may be suitable for each client relative to that client’s specific circumstances and needs.
Risk of Loss
Past performance is not indicative of future results. Therefore, you should never assume that the 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, our firm 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. There are certain
additional risks associated with investing in securities through our investment management program, as
described below:
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Alternative Investments Risk – Alternative investments typically do not correlate to the stock market,
which means they can be used to add diversification to a portfolio and help mitigate volatility.
Alternative Investments can be illiquid due to restrictions on transfer and the lack of a secondary trading
market. These investments may lack transparency as to share price, valuation, and portfolio holdings.
Complex tax structures often result in delayed tax reporting. Compared to mutual funds, private funds
are subject to less regulation and often charge higher fees. Alternative investments encompass a broad
array of strategies, each with its own unique return and risk characteristics to be considered on a case-
specific basis.
Collateralized Loan Obligation (“CLO”) Risk – A CLO is a single security backed by a pool of debt. That
pool of debt often consists of a bundle of corporate loans that are ranked below investment grade. CLOs
are securities subject to credit, liquidity, and interest rate risks. The investor will receive scheduled debt
payments from the underlying loans, assuming most of the risk if the borrowers of those loans default. A
CLO usually has multiple “tranches.” Each tranche is a piece of the CLO, and the order of the tranches
dictates in what order the investors will be paid when the underlying loan payments are made. The
tranches also dictate the associated risk since investors who are paid last have the highest overall risk of
loss. Those paid first have less risk and are therefore paid smaller interest payments—whereas those
paid last receive higher interest payments to compensate for the risk.
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 an unsystematic risk and can
be reduced through appropriate diversification. There is the risk that the company will perform poorly or
have its value reduced based on factors specific to the 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.
Cybersecurity Risk – With the increased use of technologies to conduct business, companies are
susceptible to operational, information security, and related risks. In general, information and cyber-
incidents can result from deliberate attacks or unintentional events and arise from external or internal
sources. Cyber-attacks include unauthorized access to digital systems (such as through “hacking” or
malicious software coding) for purposes of misappropriating assets or sensitive information; corrupting
data, equipment, or systems; or causing operational disruption. Cyber-attacks may also be carried out
in a manner that does not require gaining unauthorized access, such as causing denial of service
attacks on websites (making network services unavailable to intended users). Cyber-incidents may
cause disruptions and affect business operations, potentially resulting in financial losses, impediments
to trading, the inability to transact business, destruction to equipment and systems, violations of
applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or
other compensation costs, or additional compliance costs.
Duration Risk – Duration is a way to measure a bond’s price sensitivity to changes in interest rates. The
duration of a bond is determined by its maturity date, coupon rate, and call feature. Duration is a
method to compare how different bonds will react to interest rate changes. For example, if a bond has a
duration of five (5) years, it means that the value of that security will decline by approximately five
percent (5%) for every one percent (1%) increase in interest rates.
Emerging Markets Risk – The risks associated with foreign investments are heightened when investing in
emerging markets. The governments and economies of emerging market countries may show greater
instability than those of more developed countries. Such investments tend to fluctuate in price more
widely and to be less liquid than other foreign investments.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
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.
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.
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.
International Investing Risk – International investing, especially in emerging markets, involves special
risks, such as currency exchange and price fluctuations and political and economic risks.
Interval Fund Risk – Interval funds are classified as closed-end funds, but they are distinct because the
shares do not trade on the secondary market, but instead periodically the fund offers to buy back a
percentage of outstanding shares at net asset value. This results in the funds being largely illiquid. There
is no guarantee that investors will be able to sell their shares at any given time or in the desired amount.
Additionally, repurchase is done on a pro-rata basis; therefore, there is no guarantee you can redeem
the number of shares you want during a given redemption.
Liquidity Risk – Liquidity is how easily an asset or security can be bought or sold in the market and
converted to cash. Generally, the less liquid an asset is, the greater the risk that if an investor needed to
sell the asset quickly, the asset will be sold at a loss. Simple assets tend to be more liquid than complex
assets. An asset tends to be more liquid if it represents a standardized product or security and there are
many traders interested in making a market in that product or security. Some investments, like Qualified
Opportunity Zone Funds, are considered private investments and are illiquid because there is no public
market that currently exists for the investment type. Therefore, the inability to quickly sell or liquidate this
investment carries a higher risk for a loss in the investment.
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.
Margins Risk – A margin transaction occurs when an investor uses borrowed assets by using other
securities as collateral to purchase financial instruments. The effect of purchasing a security using
margin is to magnify any gains or losses sustained by the purchase of the financial instruments on
margin. Margin trading involves interest charges and risks, including the potential to lose more than
deposited or the need to deposit additional collateral in a falling market. Some Sub-Advisor strategies
may require the use of margin accounts.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
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.
Private Investments Risk – A private investment is a financial asset outside public market assets,
meaning they are not listed on an exchange. Investors often access private investments through a
private investment fund. A private investment fund is an investment company that doesn’t solicit capital
from retail investors or the public. Hedge funds and private equity funds are two of the most common
types of private investment funds. Private equity investing often has high investment minimums and
they may also have higher liquidity risks since private equity investors are expected to invest their funds
with the firm for several years, on average. Investors often utilize private investments to diversify their
portfolio and reduce overall risk exposure across specific sectors. However, because there is no major
public exchange for these investments, a fund manager may find it difficult to liquidate the investments
in a fund in times of economic stress.
REITs and Real Estate Risk – Real estate investment trusts (REITs) are popular investment vehicles that
pay dividends to investors. The value of an investment in REITs may change in response to a change in
the real estate market. REITs may subject an investment to additional risks such as decline in the value
of real estate, changes in interest rates may result in lack of available mortgage funds or other capital
and financing limits, extended vacancies of properties, increases in property taxes and operating
expenses, and changes in zoning laws and regulations. When traded like shares of stock on exchanges,
REITs can give exposure to diversified real estate holdings.
Structured Notes Risk – Structured notes are complex instruments consisting of a bond component and
an imbedded derivative component that adjusts the security’s risk-return profile. There are both
principal-at-risk and principal-protected notes. Principal-protected notes offer full principal protection,
subject to the credit risk of the issuer, even if the market is down at the note’s maturity. Principal-at-risk
notes offer no principal protection, and an investor can lose some or all of their invested principal at
maturity. A structured note will result in loss of principal if the reference asset declines by more than the
stated buffer or barrier level, either at maturity, or on a scheduled observation date. Structured notes are
classified as senior unsecured debt and are therefore subject to the risk of default. They lack liquidity, are
not listed on securities exchanges, and do not participate in dividends. Typically, the issuer will maintain
a secondary market; but there is no obligation to do so. Therefore, there may be little to no secondary
market available. To the extent a secondary market may exist, a sale in the secondary market prior to
maturity may result in a significant discount in the sale price of the note resulting in a loss of principal.
Structured notes are also subject to credit and call risks. The credit risk involves a situation where, if the
issuer were to default on its payment obligations, you may not receive any amount owed under the
structured note and you could lose your entire principal investment. Certain notes may be callable
automatically or at the option of the issuer. If a note is called, the investor will not receive any interest
payments that would have been payable for the remainder of the term of the note. Depending on the
nature of the linked asset or index, the market risk of the structured note may include changes in equity
or commodity prices, changes in interest rates or foreign exchange rates, or market volatility. After
issuance, structured notes may not be re-sold on a daily basis and thus may be difficult to value given
their complexity.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
ITEM 9 – DISCIPLINARY INFORMATION
ITEM 9 – DISCIPLINARY INFORMATION
Our firm and our financial professionals are required to disclose any legal or disciplinary events that are
material to a client's or prospective client's evaluation of us, our business or the integrity of our
management or associated persons. Information regarding our firm and associated persons is always
available by searching the firm or individuals name on the Investment Adviser Public Disclosure website:
https://adviserinfo.sec.gov/.
The firm has no disciplinary information which would be material to a client’s evaluation of us. Our principal
owner Mr. Testa has one civil disclosure related to a dismissed allegation from a former employer.
ITEM 10 – OTHER FINANCIAL INDUSTRY
ITEM 10 – OTHER FINANCIAL INDUSTRY
ACTIVITIES AND AFFILIATIONS
ACTIVITIES AND AFFILIATIONS
Tailored Wealth Solutions is not and does not have a related person that is a broker/dealer, municipal
securities dealer, government securities dealer or broker, an investment company or other pooled
investment vehicle (including a mutual fund, closed-end investment company, unit investment trust,
private investment company or "hedge fund," and offshore fund), another investment adviser or financial
planner, a futures commission merchant, commodity pool operator, or commodity trading advisor, a
banking or thrift institution, or a sponsor or syndicator of limited partnerships.
Tailored Wealth Solutions does have Investment Advisor Representatives, including control persons, who are
engaged in separate business activities as an insurance agency or agent, and a business consultant.
Clients are never under any obligation to utilize outside services or products which may be offered by their
advisors in these separate capacities. All outside activities of your advisor are disclosed in their individual
brochure supplement (ADV 2B) along with any conflicts of interest such activities may present.
Compensation received as part of an outside activity is separate from and in addition to the Advisory Fees
you pay us for Advisory Services. Please refer to Item 5 – Fees and Compensation for information regarding
fees our firm charges for Advisory Services.
Insurance Product Recommendations
Through unaffiliated insurance agencies, our financial representatives can sell other products or provide
services outside of their role as investment adviser representatives with us.
Due to the firm’s financial planning philosophy, it is common for our financial professionals to recommend
that clients utilize insurance products (for example, a fixed index annuity (“FIA”)) as part of the client’s
overall financial plan in lieu of separately managed accounts (specifically, in lieu of cash and fixed income
asset classes). You should be aware that there are a number of conflicts of interests that are present due to
our planning philosophy and recommendations to utilize insurance products in this nature.
As an estimate, our financial professionals that are registered as investment advisor representatives spend
a portion of their time on insurance sales and services a portion of their time on investment advisory
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS | ITEM 9 - DISCIPLINARY INFORMATION
services in the future. Please refer to Item 5 – Fees and Compensation and Item 14 – Client Referrals and
Other Compensation for more details.
You may therefore work with your financial professional in both their capacity as an investment adviser
representative of Tailored Wealth Solutions, as well as in their capacity as an insurance agent. As such, your
TWS financial professional, in their dual capacity as an IAR and insurance agent, may advise you to
purchase insurance products (general disability insurance, life insurance, annuities, and other insurance
products to you), and then assist you in implementing the recommendations by selling you those same
products through an insurance agency. For the reasons described below, this creates a variety of conflicts
of interest that you should be aware of.
Commissions: Although Tailored Wealth Solutions, LLC and its investment adviser representatives owe
you a fiduciary duty, it should be noted that the receipt of a commission provides a variety of incentives
for our financial professionals to recommend these products. For example, your financial professional
will earn a larger commission the more assets are invested in an annuity, therefore they are
economically incentivized to recommend that you purchase an annuity over placing those assets in a
brokerage or advisory account, which may provide lower total compensation. Our financial professional
could also be incentivized to recommend a product that pays a commission now, versus an advisory
product that pays fees over a longer period of time. As an example, all other variables held equal, a 5%
commission paid by an insurance company upon sale of a $100,000 annuity product, may be more
attractive to a financial professional than a one percent (1%) advisory fee charged on a $100,000
account paid over a period of five (5) years, despite the overall pre-tax compensation paid to the
financial professional being equal. Note that some products pay a higher street or bonus commission
than others, increasing this incentive and creating an economic incentive to favor higher fee-paying
products.
Additional Compensation: Our financial professionals also receive additional compensation or
incentives in the form of bonus commissions, gifts, meals or entertainment, reimbursement for training,
marketing, education, advertising, or travel expenses associated with sponsored conferences or events.
The exact compensation cannot be accurately calculated at the time of recommendation because they
rely on sales goals, but you should be aware that there are a variety of forms of indirect compensation
paid by carriers and insurance marketing organizations, and this compensation creates a conflict of
interest.
In addition, each of the individual insurance carriers that our financial professionals work with may also
separately provide incentive-based bonuses or awards in exchange for sales-related production over
specific periods of time, which is a conflict of interest. They may also provide indirect compensation by
providing marketing assistance, business development tools, technology, back office/operations
support, business succession planning, business conferences, and incentive trips. These incentive
programs do not directly affect fees paid by the client. Although some of these services can benefit a
client, other services obtained by our IARs such as marketing assistance, business development, and
incentive trips, will not benefit an existing client and is a conflict of interest.
At times, our financial professionals receive expense reimbursement for travel and/or marketing
expenses from distributors of investment and/or insurance products. Travel expense reimbursements
are a result of attendance at due diligence and/or investment training events hosted by product
sponsors. Marketing expense reimbursements are the result of informal expense sharing arrangements
in which product sponsors will underwrite costs incurred for marketing, such as client appreciation
events, advertising, publishing, and seminar expenses. Although receipt of these travel and marketing
expense reimbursements are not predicated upon specific sales quotas, the product sponsor
reimbursements are made by those sponsors for which sales have been made or for which it is
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
anticipated sales will be made. This creates a conflict of interest in that there is an incentive to
recommend certain products and investments based on the receipt of this compensation instead of what
is in the best interest of clients.
Exchanges & Replacement Recommendations: Your financial professional may recommend that you
exchange or replace an existing annuity with a new annuity if they believe it is appropriate. You should
be aware that the firm and financial professional receive additional commission when an exchange or
replacement is made, in the form of commissions and bonuses, and other additional compensation
described above. You may also incur a surrender charge on the old annuity. The new purchase be also
subject to the commencement of a new surrender period, lose existing benefits, such as accumulated
value, death, living or other contractual benefits, or be subject to increased fees, or additional charges
for riders and similar product enhancements.
The sale of commission-based products is supervised by the firm’s Chief Executive Officer, and the firm
makes periodic reviews of its insurance recommendations to ensure that our financial professionals act in
accordance with our fiduciary duty. If you have any questions or concerns about annuity recommendations
made during the financial planning process, we encourage you to immediately bring them to the attention
of the Chief Executive Officer.
Finally, you should be aware that there are other insurance products that are offered by other insurance
agents other than those recommended by our financial professionals. You are under no obligation to
implement any insurance or annuity transaction through our financial professionals.
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
ITEM 11 – CODE OF ETHICS, PARTICIPATION IN
ITEM 11 – CODE OF ETHICS, PARTICIPATION IN
CLIENT TRANSACTIONS AND PERSONAL TRADING
CLIENT TRANSACTIONS AND PERSONAL TRADING
Code of Ethics Summary
An investment adviser is considered a fiduciary and has a fiduciary duty to all clients. Tailored Wealth
Solutions has established a Code of Ethics to comply with the requirements of the securities laws and
regulations that reflects its fiduciary obligations and those of its supervised persons. The Code of Ethics also
requires compliance with federal securities laws. Tailored Wealth Solutions’ Code of Ethics covers all
individuals that are classified as “supervised persons”. All employees, officers, directors and investment
adviser representatives are classified as supervised persons. Tailored Wealth Solutions requires its
supervised persons to consistently act in your best interest in all advisory activities.Tailored Wealth Solutions
imposes certain requirements on its affiliates and supervised persons to ensure that they meet the firm’s
fiduciary responsibilities to you. The standard of conduct required is higher than ordinarily required and
encountered in commercial business.
This section is intended to provide a summary description of the Code of Ethics of Tailored Wealth Solutions.
If you wish to review the Code of Ethics in its entirety, you should send us a written request and upon receipt
of your request, we will promptly provide a copy of the Code of Ethics to you.
Affiliate and Employee Personal Securities Transactions Disclosure
Tailored Wealth Solutions or supervised persons of the firm can buy or sell for their personal accounts
investments identical to those recommended to clients. This creates a conflict of interest. It is the express
policy of Tailored Wealth Solutions that all persons supervised in any manner by our firm must place clients’
interests ahead of their own when implementing personal investments. As is required by our internal
procedures manual, Tailored Wealth Solutions and its supervised persons will not buy or sell securities for
their personal account(s) where their decision is derived, in whole or in part, by information obtained as a
result of employment or association with our firm unless the information is also available to the investing
public upon reasonable inquiry.
We are now and will continue to be in compliance with applicable state and federal rules and regulations.
To prevent conflicts of interest, we have developed written supervisory procedures that include personal
investment and trading policies for our representatives, employees and their immediate family members
(collectively, supervised persons). Any supervised person not observing our policies is subject to sanctions
up to and including termination.
ITEM 11 – CODE OF ETHICS, PARTICIPATION IN CLIENT TRANSACTIONS AND PERSONAL TRADING
ITEM 12 – BROKERAGE PRACTICES
ITEM 12 – BROKERAGE PRACTICES
Best execution does not necessarily mean that clients receive the lowest possible commission costs but
that the qualitative execution is best. In other words, all conditions considered, the transaction execution is
in your best interest. When considering best execution, we look at a number of factors besides prices and
rates including, but not limited to:
Execution capabilities (e.g., market expertise, ease/reliability/timeliness of execution, responsiveness,
integration with our existing systems, ease of monitoring investments)
Products and services offered (e.g., investment programs, back-office services, technology, regulatory
compliance assistance, research and analytic services)
Financial strength, stability and responsibility
Reputation and integrity
Ability to maintain confidentiality
We exercise reasonable due diligence to make certain that best execution is obtained for all clients when
implementing any transaction by considering the back-office services, technology and pricing of services
offered.
At least annually, we will review alternative custodians in the marketplace for comparison to the currently
used custodian, evaluating criteria such as overall expertise, cost competitiveness, and financial condition.
Quality of execution for custodians will be reviewed through trade journal evaluations.
We recommend the brokerage and custodial services of Schwab Institutional, a division of Charles Schwab
& Co., Inc. ("Schwab Institutional"), a securities broker-dealer and a member of NYSE/SIPC. Clients are
advised that there may be transaction charges involved when purchasing or selling securities. Our firm
does not share in any portion of the brokerage fees/transaction charges imposed by Schwab Institutional.
Additionally, the commission/transaction fees charged by Schwab Institutional may be higher or lower than
those charged by other broker-dealer/custodians.
Schwab Institutional provides our firm with access to its institutional trading and operations services, which
are typically not available to Schwab retail investors. These services generally are available to independent
investment advisers at no charge to them so long as a total of at least $10 million of the adviser's clients
account assets are maintained at Schwab Institutional. Schwab Institutional services may include research,
brokerage, custody, access to mutual funds and other investments that are otherwise available only to
institutional investors or would require significantly higher minimum initial investments. Schwab Institutional
also makes available to our firm other products and services that benefit our firm but may not benefit its
clients' accounts. These include software and other technology that provide access to client account data
(such as trade confirmations and account statements), facilitate trade execution, provide research, pricing
information and other market data, and provide custodial services which facilitate payment of our firm's
fees from its clients' accounts and clients reports. The availability to our firm of the foregoing products and
services is not contingent upon our firm committing to Schwab Institutional any specific amount of business
(assets in custody or trading).
We believe that Schwab Institutional provides quality execution services at competitive prices. Price is not
the sole factor we consider in evaluating best execution. We also consider the quality of the brokerage
services provided by Schwab Institutional, including the value of research provided, the firm's reputation,
execution capabilities, commission rates, and responsiveness to our clients and our firm.
ITEM 12 – BROKERAGE PRACTICES
In recognition of the value of research services and additional brokerage products and services Schwab
Institutional provides, you may pay higher commissions and/or trading costs than those that may be
available elsewhere.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as
brokerage services or research.
Non-Soft Dollar Research and Additional Benefits
Although not a material consideration when determining whether to recommend that a client utilize the
services of a particular broker-dealer/custodian, TWS may receive from Schwab (or another broker-
dealer/custodian, investment manager, platform or fund sponsor, or vendor) without cost (and/or at a
discount) support services and/or products, certain of which assist TWS to better monitor and service client
accounts maintained at such institutions. Included within the support services that may be obtained by
TWS may be investment-related research, pricing information and market data, software and other
technology that provide access to client account data, compliance and/or practice management-related
publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences,
meetings, and other educational and/or social events, marketing support-including client events, computer
hardware and/or software and/or other products used by TWS in furtherance of its investment advisory
business operations.
As indicated above, certain of the support services and/or products that may be received may assist TWS in
managing and administering client accounts. Others do not directly provide such assistance but rather
assist TWS to manage and further develop its business enterprise.
TWS’ clients do not pay more for investment transactions effected and/or assets maintained at Schwab
because of this arrangement. There is no corresponding commitment made by TWS to Schwab or any other
any entity to invest any specific amount or percentage of client assets in any specific mutual funds,
securities or other investment products as result of the above arrangement.
Directed Brokerage
TWS recommends that its clients utilize the brokerage and custodial services provided by Schwab. TWS
generally does not accept directed brokerage arrangements (when a client requires that account
transactions be affected through a specific broker-dealer). In such client directed arrangements, the client
will negotiate terms and arrangements for their account with that broker-dealer, and TWS will not seek
better execution services or prices from other broker-dealers or be able to "batch" the client’s transactions
for execution through other broker-dealers with orders for other accounts managed by TWS As a result, a
client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable
net prices, on transactions for the account than would otherwise be the case. Please Note: In the event that
the client directs TWS to effect securities transactions for the client’s accounts through a specific broker-
dealer, the client correspondingly acknowledges that such direction may cause the accounts to incur
higher commissions or transaction costs than the accounts would otherwise incur had the client
determined to effect account transactions through alternative clearing arrangements that may be
available through TWS. Higher transaction costs adversely impact account performance. Please Also Note:
Transactions for directed accounts will generally be executed following the execution of portfolio
transactions for non-directed accounts.
Trade Away/Prime Broker Fees
Relative our discretionary investment management services (and sub-advisors), when beneficial to the
ITEM 12 – BROKERAGE PRACTICES
client, TWS or sub-advisors, may purchase individual fixed income securities through broker-dealers other
than the account custodian, in which event, the client generally will incur the fee (commission, mark-up,
mark-down) charged by the executing broker-dealer and potentially, a separate "trade away" and/or prime
broker fee charged by the account custodian.
Block Trading Policy
We often elect to purchase or sell the same securities for several clients at approximately the same time.
This process is referred to as aggregating orders, batch trading or block trading and is used by our firm
when Tailored Wealth Solutions believes such action may prove advantageous to clients. If and when we
aggregate client orders, allocating securities among client Accounts is done on a fair and equitable basis.
Typically, the process of aggregating client orders is done in order to achieve better execution, to negotiate
more favorable commission rates or to allocate orders among clients on a more equitable basis in order to
avoid differences in prices and transaction fees or other transaction costs that might be obtained when
orders are placed independently.
Tailored Wealth Solutions uses the pro rata allocation method for transaction allocation. Under this
procedure, pro rata trade allocation means an allocation of the trade at issue among applicable advisory
clients in amounts that are proportional to the participating advisory client’s intended investable assets.
Tailored Wealth Solutions will calculate the pro rata share of each transaction included in a block order and
assign the appropriate number of shares of each allocated transaction executed for the client’s Account.
If and when we determine to aggregate client orders for the purchase or sale of securities, including
securities in which Tailored Wealth Solutions or our associated persons may invest, we will do so in
accordance with the parameters set forth in the SEC No-Action Letter, SMC Capital, Inc. Neither we nor our
associated persons receive any additional compensation as a result of block trades.
ITEM 13 – REVIEW OF ACCOUNTS
ITEM 13 – REVIEW OF ACCOUNTS
Account Reviews and Reviewers
Managed Accounts are reviewed at least annually but reviews may occur more frequently based on your
IARs assessment of your financial needs and investment strategy. While the calendar is the main triggering
factor, reviews can also be conducted at your request. Account reviews will include investment strategy and
objectives review and making a change if strategy and objectives have changed. Reviews are conducted
by your Advisor on record, with reviews performed in accordance with your investment goals and
objectives.
Statements and Reports
For our asset management services, you are provided with transaction confirmation notices and regular
quarterly Account statements in writing directly from the qualified custodian. Additionally, Tailored Wealth
Solutions may provide position or performance reports to you quarterly and upon request. Financial
Planning client receive reports as agreed in the Financial Planning Agreement with us which may or may
not be ongoing.
You are encouraged to always compare any reports or statements provided by us or a co-adviser against
the Account statements delivered from the qualified custodian. When you have questions about your
Account statement, you should contact our firm and the qualified custodian preparing the statement.
ITEM 12 – BROKERAGE PRACTICES | ITEM 13 - REVIEW OF ACCOUNTS
ITEM 14 – CLIENT REFERRALS AND OTHER
ITEM 14 – CLIENT REFERRALS AND OTHER
COMPENSATION
COMPENSATION
Tailored Wealth Solutions does not currently participate in referral arrangements with affiliated and
unaffiliated third parties. In the event we engage in such arrangement, before we compensate a third party
for referrals, clear and prominent disclosures are provided to you on the material terms of the
compensation arrangement between the referral source and our Firm, whether there is any affiliation
between the referral source and our Firm, and whether the client bears any costs with respect to the referral.
Additionally, we disclose that fees paid by a referred client may differ from fees paid by other similarly
situated clients who are not introduced to Tailored Wealth Solutions through a referral. We strongly
recommend prospective clients review the disclosures carefully to help address any potential conflicts of
interest.
As disclosed under the "Fees and Compensation" section in this Brochure, our financial professionals
providing investment advice on behalf of our firm are also licensed insurance agents and earn
commission-based compensation for selling insurance products. Our representatives who are licensed
insurance agents also receive certain benefits from insurance carriers, including small gifts such as fruit
baskets or snacks, event sponsorships, or bonuses. These practices present conflicts of interest because our
representatives who are licensed insurance agents have an incentive to recommend insurance products,
as well as insurance products through specific carriers, to you based on the receipt of these benefits. For
information on how we address the conflicts associated with the sale of insurance products, please refer to
the "Fees and Compensation" and "Other Financial Industry Activities and Affiliations" sections of this
Brochure.
The Firm and its supervised persons may receive certain benefits from third-party managers or vendors,
including sales awards and trips, based in part on the amount of advisory business directed to the third-
party manager or business with the vendor. This presents a conflict of interest because we have an
incentive to recommend the services of the third-party manager or vendor. We address this conflict by
ensuring the recommendation for a third party manager is in your best interest.
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION
ITEM 15 – CUSTODY
ITEM 15 – CUSTODY
Custody, as it applies to investment advisors, has been defined by regulators as having access to or control
over client funds and/or securities. In other words, custody is not limited to physically holding client funds
and securities. If an investment adviser has the ability to access or control client funds or securities, the
investment adviser is deemed to have custody and must ensure proper procedures are implemented.
For all of our managed accounts, we have established procedures to ensure all client funds and securities
are held by a qualified custodian in a separate account for each client under that client’s name. Clients 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.Finally, account statements
are delivered directly from the qualified custodian to each client, at least quarterly.Clients should carefully
review those statements and are urged to compare the statements against reports received from Tailored
Wealth Solutions. When clients have questions about their account statements, they should contact
Tailored Wealth Solutions or the qualified custodian preparing the statement.
ITEM 16 – INVESTMENT DISCRETION
ITEM 16 – INVESTMENT DISCRETION
When providing asset management services, Tailored Wealth Solutions maintains trading authorization
over your Account and can provide management services on a discretionary basis. When discretionary
authority is granted, we will have the authority to determine the type of securities and the amount of
securities that can be bought or sold for your portfolio without obtaining your consent for each transaction.
You also give Tailored Wealth Solutions discretionary authority to select third party asset managers and to
change managers as needed. However, it is the policy of Tailored Wealth Solutions to consult with you prior
to making significant changes in the Account even when discretionary trading authority is granted.
If you decide to grant trading authorization on a non-discretionary basis, we will be required to contact you
prior to implementing changes in your Account. Therefore, you will be contacted and required to accept or
reject our investment recommendations including:
The security being recommended
The number of shares or units
Whether to buy or sell
Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing
of buying or selling an investment and the price at which the investment is bought or sold.
If your Accounts are managed on a non-discretionary basis, “Client Managed” 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.
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 Tailored
Wealth Solutions so long as the limitations are specifically set forth or included as an attachment to the
client agreement.
ITEM 15 – CUSTODY | ITEM 16 - INVESTMENT DISCRETION
ITEM 17 – VOTING CLIENT SECURITIES
ITEM 17 – VOTING CLIENT SECURITIES
Tailored Wealth Solutions does not vote proxies on behalf of Clients. We have determined that taking on the
responsibility for voting client securities does not add enough value to the services provided to you to justify
the additional compliance and regulatory costs associated with voting client securities. Therefore, it is your
responsibility to vote all proxies for securities held in Account.
You will receive proxies directly from the qualified custodian or transfer agent; we will not provide you with
the proxies. You are encouraged to read through the information provided with the proxy-voting documents
and make a determination based on the information provided.
ITEM 18 – FINANCIAL INFORMATION
ITEM 18 – FINANCIAL INFORMATION
This Item 18 is not applicable to this brochure. Tailored Wealth Solutions 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,
Tailored Wealth Solutions has not been the subject of a bankruptcy petition at any time.
ITEM 17 – VOTING CLIENT SECURITIES | ITEM 18 - FINANCIAL INFORMATION