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TAM Financial Advisors
Item 1 – Cover Page
TAM Financial Advisors
1441 Pleasant Lake Road
Annapolis, MD 21409
410-349-4484/401-349-4480 (fax)
www.tamfinancial.net
February 5, 2026
This firm brochure (“brochure”) provides information about the qualifications and business practices
of TAM Financial Advisors, LLC, dba TAM Financial Advisors (“TAM”). If you have any questions about
the contents of this brochure, please contact us at 410-349-4484 or info@tamfinancial.net. 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. Delivery of this brochure does not
relieve TAM of any other disclosure obligations under any federal or state laws or regulations.
Additional information about TAM is available on the SEC’s website at www.adviserinfo.sec.gov.
The firm’s searchable CRD No. is 125496.
TAM is a registered investment advisor with the SEC. Registration of an investment advisor does not
imply any level of skill or training. The oral and written communications of an advisor provide you with
information about which you determine to hire or retain an advisor.
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Item 2 – Material Changes
This item discusses material changes to this brochure since our last annual update made on
March 25, 2025. Since that date, we have made the following material changes:
The assets under management totals have been updated.
We will ensure that all current clients receive a Summary of Material Changes to this and
subsequent brochures within 120 days of the close of our business’ fiscal year. A Summary
of Material Changes is also included with our brochure on the SEC’s website at
www.advisorinfo,sec.gov. The searchable IARD/CRD number for our firm is 125496. We
may further provide other ongoing disclosure information about material changes as
necessary and will further provide you with a new brochure as necessary based on changes
or new information, at any time, and without charge.
Currently, our brochure may be requested free of charge by contacting Michael L. Marvin,
CFP®, President of TAM, at 410-349-4484 or by e-mail to mmarvin@tamfinancial.net. Our
brochure is also available on our web site, www.tamfinancial.net, free of charge.
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Item 3 – Table of Contents
Contents
Item 1 – Cover Page .............................................................................................................................................. 1
Item 2 – Material Changes ................................................................................................................................. 2
Item 3 – Table of Contents ................................................................................................................................. 3
Item 4 – Advisory Business ............................................................................................................................... 4
Item 5 – Fees and Compensation .................................................................................................................... 6
Item 6 – Performance-Based Fees and Side-By-Side Management ................................................... 8
Item 7 – Types of Clients .................................................................................................................................... 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................ 9
Item 9 – Disciplinary Information ................................................................................................................10
Item 10 – Other Financial Industry Activities and Affiliations ..........................................................10
Item 11 – Code of Ethics ...................................................................................................................................10
Item 12 – Brokerage Practices .......................................................................................................................12
Item 13 – Review of Accounts ........................................................................................................................12
Item 14 – Client Referrals and Other Compensation .............................................................................13
Item 15 – Custody ...............................................................................................................................................14
Item 16 – Investment Discretion ...................................................................................................................14
Item 17 – Voting Client Securities .............................................................................................................15
Item 18 – Financial Information ................................................................................................................15
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Item 4 – Advisory Business
TAM is a financial planning and investment management firm in business since 2004.
We are registered as an investment advisor with the SEC. Our firm offers a variety of advisory
and financial planning services including, but not limited to, retirement, education and estate
planning, small business retirement plan development and other small business strategic
services, and supervisory investment management services.
The information contained in this brochure describes our investment advisory services,
practices, and fees in further detail. Please refer to the description of each investment
advisory service we offer below for information on how we tailor our services to the needs
of our clients. As used throughout this firm brochure, the words “we,” “our,” “firm,” “TAM,”
“TAM Financial,” and “us” refer to TAM Financial Advisors, and the words “you,” “your,” and
“client” refer to you as either a client or prospective client of our firm.
TAM is wholly owned by Michael L. Marvin, CFP®, its sole principal and President. Mr.
Marvin was born in 1962 in the State of Washington. He holds a Bachelor’s Degree from the
University of Washington, awarded in 1985; a Master's Degree from The Johns Hopkins
University, awarded in 1998; and an Executive Financial Planning certification from
Georgetown University, awarded in 2003. In addition to being President of TAM since 2004,
Michael was President of The Business Council for Sustainable Energy from 1996-2004,
served as the Director of Governmental and Legislative Affairs for the American Wind Energy
Association from 1990-1996, and served two Members of Congress as Legislative Director
and Chief of Staff. More information regarding Michael’s business background and that of
other investment advisor representatives of our firm is available in our Form ADV Part 2B
brochure supplement (“brochure supplement”). A copy of the brochure supplement for the
individual advisor(s) you work with at TAM will be provided to you prior to or at the time
you engage our firm for services.
All employees of our firm who perform investment advisory functions are required to have
an undergraduate degree, to have passed the Series 65 (or equivalent) examination, and
either have or be working toward a Certified Financial Planner (CFP®) or Chartered
Financial Analyst (CFA®) designation.
TAM is a fee-only advisory firm. TAM agrees to restrict its compensation solely and
exclusively to the professional fees it receives directly from its clients for its advisory
services. Whenever TAM recommends that a client purchase a specific security, insurance or
financial product, or utilize the services of a specific custodian, TAM and its employees will
not accept any sales commissions, prizes, vacations, trips, gifts or meals valued in excess of
$100 from those specific vendors, custodians, or service providers.
A description of each of our services is as follows:
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Investment Management Services.
Our investment management services are tailored to each individual client’s investment goals
and needs. The needs considered include age, risk tolerance, health, employment status,
financial goals, and current cash flow requirements, among others. TAM Financial does not
have a template batch of portfolios, nor does it employ a “cookie cutter” approach. In
consultation with the client, TAM develops an individualized Investment Policy Statement
for each client that outlines the manner in which a client’s assets are to be invested. Clients
are free to impose restrictions on investing in certain securities or types of securities, and
that issue is addressed in each client’s Investment Policy Statement. We will then manage
your portfolio and assets on an ongoing basis in accordance with the Investment Policy
Statement. Your unique Investment Policy Statement will be formally reviewed periodically,
but no less than annually by our firm, in consultation with the client.
Financial Planning Services - Personal Retirement Plans and Personal Financial Plans.
We also offer personal retirement plans and personal financial plans. These planning services
may, at our discretion, be included within our investment management services and may be
made available separately to clients, either on a one-time or annual basis.
A personal retirement plan usually includes, but is not necessarily limited to: quantification
of goals and objectives; confirmation of planning assumptions; detailing client assets,
liabilities, savings contributions, and net worth; estimating retirement expenses and income;
completing various scenarios that allow client flexibility with respect to tax rates, inflation,
investment return, retirement age, age at death, and more; and conducting Monte Carlo
analyses on most likely retirement scenarios. It may also include reviewing existing
investments for appropriateness given time horizon and risk profile.
A personal financial plan includes all of the elements of a personal retirement plan as well as:
a review of education costs and savings options; an analysis of asset and family protection
with a review of life, disability, liability, home, and long-term care insurance (review of any
existing policies and/or recommend policies, if needed); an examination of debt and
liabilities; a review of stock options (if any); a review of estate planning documents, including
will, durable power of attorney for health care, advance medical directive, various trusts as
needed; and an examination of other unique circumstances deemed important to the client.
Pension Consulting Services.
We offer pension consulting services to employee benefit plans and their fiduciaries based
upon the needs of the plan and the services requested by the plan sponsor or named
fiduciary. In general, these services may include an existing plan review, investment policy
statement formulation and adherence review/monitoring, asset allocation advice, non-
discretionary
investment
investment management services (as described above),
performance/expense monitoring and benchmarking studies, on-going consulting,
compliance, vendor selection and interviewing assistance, and other related communication
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and education services. Upon request, we will assist the plan sponsor in providing
meaningful information, education, and seminars regarding the retirement plan and general
investment concepts to plan participants.
NOTE: Certain clients/plans we may provide services to are regulated under the Employee
Retirement Income Security Act of 1974 (“ERISA”). We will provide pension consulting
services to the plan sponsor and/or fiduciaries as described above for the fees set forth in
Item 5 of this brochure. The consulting services we provide are advisory in nature. In
providing services to any plan and its underlying participants, our status is that of an
investment adviser registered with the SEC. We are not subject to any disqualifications under
Section 411 of ERISA. In performing fiduciary services, we are acting as a fiduciary of the
Plan as defined in Section 3(21) under ERISA, only. In all cases, our status as a fiduciary under
ERISA is clearly disclosed in a written advisory agreement. If there is any discrepancy
between the disclosures in this paragraph and the advisory agreement, the advisory
agreement shall govern.
We generally offer advice on investments in equity securities (stocks), corporate debt
securities (bonds), commercial paper, municipal securities, investment company securities
(e.g., mutual funds, variable annuities, variable life insurance, etc.), options, United States
government securities, and exchange traded funds (ETFs). We may also offer the client
investment advice regarding (i) any legacy assets that pre-exist the client’s engagement of
our firm and (ii) other types of securities or non-securities based assets as may be
specifically requested by the client.
We do not participate in or sponsor any wrap fee program(s).
As of December 31, 2025, TAM managed approximately $171,310,289.43 of client assets on
a discretionary basis and $9,717,510.16 of client assets on a non-discretionary basis.
Item 5 – Fees and Compensation
The specific manner in which our fees are charged is established in a written advisory
agreement with the client. A description of the fees applicable to each of our advisory
services is as follows:
Investment Management Services.
TAM will generally bill its investment management advisory fees quarterly in arrears, based
on the market value of the assets under management in your account (as determined by the
independent qualified custodian) on the last day of the previous quarter in accordance with
the below fee schedule. Our advisory fees shall be prorated for each capital contribution of
$100,000 or greater made during the applicable calendar quarter. Accounts initiated or
terminated during a calendar quarter will be charged a prorated fee.
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INVESTMENT MANAGEMENT FEE SCHEDULE
Asset Under Management
Quarterly Fee/ Annual Fee
First $1,000,000 ................................................................. 0.25 % /1.00 %
Next $1,000,001 to $2,000,000 ..................................... 0.20 % /0.80 %
Over $2,000,001 ................................................................... 0.15 %/0.60%
Investment management clients typically authorize our firm and the independent qualified
custodian(s) of the client’s account(s) in writing to withdraw our advisory fees from the
client’s account(s) and then electronically transfer these fees to TAM. In the case of direct
fee deduction, clients are issued a courtesy invoice followed by a 15-day period to raise
questions or disputes before our advisory fees are withdrawn. TAM may also offer
investment management clients the option of traditional direct paper or electronic invoicing
of its advisory fees.
TAM’s advisory fees are dependent on the scope of work and amount of time invested in
managing the client’s assets. Fees for (1) investment management services, and (2)
managing investment advisory accounts not involved in such investment supervisory
services are charged quarterly in arrears as a percentage of assets under management (see
fee schedule above).
Financial Planning Services – Personal Retirement Plans and Personal Financial Plans.
Fees for one-time or annual personal financial planning or personal retirement planning are
charged either hourly or as a flat rate, and all terms of such engagements are set forth in a
written advisory agreement with the client. Our hourly fee is typically $325. Flat fees for the
development of a personal financial or retirement plan typically range between $2,500-
$5,000, depending on the complexity of a client's financial situation or a client’s desire for
additional analysis. Flat fees are negotiated with the client in advance of the delivery of
services and are agreed to in our written advisory agreement with the client.
Pension Consulting Services.
Our fees for pension consulting services may consist of fixed fees (typically ranging from
$1,000 - $10,000 annually), hourly charges (typically ranging from $150 - $325 per hour)
and/or asset based advisory fees based on a percentage of the market value of the plan’s
assets (in accordance with the fees for investment management services described above).
All fixed and hourly fees are invoiced to the client and are payable quarterly, in arrears within
15 days from the date of the invoice. Asset based advisory fees will be withdrawn from the
client’s account(s) (on the client’s written authorization for such direct fee withdrawals) and
then electronically transferred to TAM. In the case of direct fee deduction, clients are issued a
courtesy invoice followed by a 15-day period to raise questions or disputes before our
advisory fees are withdrawn. TAM may also offer pension consulting clients the option of
traditional direct paper or electronic invoicing of its asset based advisory fees.
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The specific fee structure and rate applicable to the client’s account will vary based upon the
nature of the pension consulting services selected, complexity of the engagement, and our
expectation of the time and firm resources necessary to provide services to the client, among
other factors. Fees may vary outside the typical ranges stated above.
Clients may terminate any of TAM’s investment management, financial planning or
pension consulting services at any time and for any reason on written notice to TAM.
Upon termination of any account, any prepaid but unearned fees will be promptly refunded,
and we will waive 100% of any earned but unpaid fees incurred by the client during the
terminating billing period. In general, all of our advisory and planning fees are charged in
arrears; no fees are charged or paid in advance of services provided, and clients may decline
payment if TAM Financial does not provide satisfactory product or service (in accordance
with written contract).
All fees are subject to negotiation and certain clients may pay fees which vary from our
typical fee rates and fee ranges disclosed above. While we believe our fees to be fair and
reasonable, clients are advised that similar services may be available for a lower cost.
TAM’s fees are exclusive of brokerage commissions, transaction fees, and other
related costs and expenses, which shall be borne by the client. Clients may incur certain
charges imposed by custodians, brokers, third party money managers, and other third
parties service providers such as advisory fees, custodial/brokerage fees and commissions,
deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund
transfer fees, and other fees and taxes on brokerage accounts and securities transactions.
Mutual funds and exchange traded funds may also charge internal fees, which are disclosed
in a fund’s prospectus. Such charges, fees and commissions are separate and in addition to
TAM’s advisory fees. TAM does not receive any portion of these commissions, fees, and costs.
Clients have the option to purchase investment products that TAM recommends through
brokers or agents that are not affiliated with our firm.
TAM is a fee-only advisor. Except as set forth in Item 12, neither the firm nor its employees
accepts any gifts, incentives or other financial remuneration for the recommendation or
purchase of any securities, insurance products, or services. TAM is committed to its fiduciary
relationship with its clients.
Item 6 – Performance-Based Fees and Side-By-Side Management
TAM does not charge any performance-based fees (fees based on a share of capital gains on
or capital appreciation of the assets of a client). Accordingly, the firm does not engage in side-
by-side management (simultaneous management of accounts subject to performance-based
fees and accounts not subject to such fees).
Item 7 – Types of Clients
TAM provides financial planning, investment management and pension consulting services to
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individuals, high net worth individuals, corporate pension and profit-sharing plans, Taft-
Hartley plans, charitable institutions, foundations, endowments, municipalities, registered
mutual funds, private investment funds, trust programs, and other U.S. and international
institutions.
Generally, TAM only accepts clients with more than $1,000,000 in assets under management
but may accept clients with lower assets under management at its sole discretion.
The minimum annual fee for investment management and ongoing (annual) comprehensive
financial planning services is usually $10,000, although fee minimums may be negotiable at
TAM’s sole discretion, based on client circumstances, prior arrangements with TAM, and any
other factors TAM may consider to be relevant.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
TAM believes a diverse portfolio of investments is the central component to mitigating—but
not eliminating—market risk associated with investing. Portfolio design and asset allocation
are the most important components to manage risk over the long term, and asset allocation
is a core part of TAM’s strategic approach.
Beyond asset allocation, other investment factors that TAM considers include, but are not
limited to, minimizing total portfolio expenses and maximizing tax efficiency.
TAM works primarily with moderate and conservative investors and is generally not suited
for any client with an aggressive investor profile. The company employs a variety of risk
mitigation methodologies, including the use of options (calls and puts), to reduce the
volatility of a client’s portfolio. The use of options—even in a more defensive way—is not a
tool for all investors, and TAM works with institutional clients where the use of any options
is prohibited in the Investment Policy Statement.
TAM believes that dividends are a critical component of total portfolio return. Total return
is defined as after-tax, after-inflation returns, and dividends have represented nearly 40% of
total S&P 500 returns since 1950. In most portfolios, total return includes dividends, interest
and any capital gains; in portfolios that include “covered call” options, an additional revenue
stream is created.
TAM also generally subscribes to a mean reversion theory of investing to identify companies,
sectors and asset classes that have more or less attractiveness relative to their historical
valuations. This has been described as a value-oriented approach to investing, as has been
outlined in detail in Security Analysis by Benjamin Graham and David Dodd (1934).
All investment philosophies carry the risk of capital loss. Some of the risks may include, but
are not limited to, the following: there is no assurance that a company or sector will return
to historical valuations; macroeconomic conditions could lead to a decrease in the value of
equities or bonds in all sectors; a change in valuations could be a sign a company or sector
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no longer has the prospects it once did; reversion to the mean can take longer for different
asset classes, and the duration for each cycle can vary widely; and external forces (such as
changes in government regulation) could permanently alter valuations.
Investing in securities involves risk of loss that clients should be prepared to bear.
TAM’s strategy involves the active trading of securities. Frequent trading can affect
investment performance, particularly through increased brokerage and other transactions
costs and taxes.
Item 9 – Disciplinary Information
As a registered investment advisor, TAM is required to disclose all material facts regarding
any legal or disciplinary events that would be material to your evaluation of the firm or the
integrity of its management personnel. TAM has no information to disclose that is applicable
to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
TAM and its Principal, Michael L. Marvin, CFP®, have no other financial industry activities
or affiliations. TAM is a fiduciary to its clients and does not engage in activities or affiliations
that create any conflict of interest.
TAM offers a suite of fee-only financial planning services that includes, but is not limited to,
retirement, education financing, business strategic development, estate planning, and more.
As described above, TAM is a fee-only advisory firm. TAM restricts its compensation solely
and exclusively to the professional fees it receives directly from its clients for professional
services rendered to its clients.
Item 11 – Code of Ethics
TAM has adopted a Code of Ethics (“Code”) for all supervised persons of the firm describing
its high standard of business conduct and fiduciary duty to its clients. The Code includes
provisions relating to the confidentiality of client information, a prohibition on insider
trading, a prohibition of rumor mongering, and restrictions on the acceptance of significant
gifts and personal securities trading procedures, among other things. All supervised persons
at TAM must acknowledge the terms of the Code annually, or as amended.
TAM anticipates that, in appropriate circumstances, and consistent with clients’ investment
objectives, it will cause accounts over which TAM has management authority to effect and
will recommend to investment advisory clients or prospective clients, the purchase or sale
of securities in which TAM, its affiliates and/or clients, directly or indirectly, have a position
of interest. TAM’s employees and persons associated with TAM are required to follow TAM’s
Code. Subject to satisfying this policy and applicable laws, officers, directors and employees
of TAM and its affiliates may trade for their own accounts in securities which are
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recommended to and/or purchased for clients.
The Code is designed to assure that the personal securities transactions, activities and
interests of the employees of TAM will not interfere with (i) making decisions in the best
interest of 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,
based upon a determination that these would materially not interfere with the best interest
of TAM’s clients. In addition, the Code requires pre-clearance of many transactions, and
restricts trading in close proximity to client trading activity. Nonetheless, because the Code
in some circumstances would permit 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 held by an employee. Employee trading is continually monitored under the Code to
reasonably prevent conflicts of interest between TAM and its clients.
Certain affiliated accounts may trade in the same securities with client accounts on an
aggregated basis when consistent with TAM’s obligation of best execution. In such
circumstances, the affiliated and client accounts will share commission costs equally and
receive securities at a total average price. TAM will retain records of the trade order
(specifying each participating account) and its allocation, which will be completed prior to
the entry of the aggregated order. Completed orders will be allocated as specified in the
initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions
will be explained on the order.
TAM Financial Advisors’ clients or prospective clients may request a copy of the firm's Code
of Ethics by contacting Michael L. Marvin, CFP® using the contact information found on the
cover page of this brochure.
Securities purchased for clients are purchased simultaneous with or prior to any purchases
made by TAM's principal in accordance with TAM's compliance manual (copy available upon
request). Securities sold for clients are sold simultaneously with or before securities sold
for TAM's principal.
It is TAM’s policy that it will not affect any principal or agency cross securities transactions
for client accounts. TAM will also refrain from cross trades between 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. A principal transaction may also be deemed to have occurred if a
security is crossed between an affiliated hedge fund and another client account. An agency
cross transaction is defined as a transaction where a person acts as an investment adviser in
relation to a transaction in which the investment adviser, or any person controlled by or
under common control with the investment adviser, acts as broker for both the advisory
client and for another person on the other side of the transaction.
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Item 12 – Brokerage Practices
TAM typically recommends that its clients engage Charles Schwab & Co., Inc., member
FINRA/SIPC (“Schwab”), an unaffiliated SEC-registered broker-dealer, as the primary
custodian and executing broker for their accounts. The use of a single custodian may mean
that not all individual transactions will receive the best execution. Schwab is a discount
broker that generally offers lower-than-average commissions and fees, but it is possible
that other brokers may still offer lower fees and commissions.
There are several factors that TAM considers when recommending broker-dealers for client
transactions and determining the reasonableness of their compensation (e.g., commissions),
including price, execution capabilities, and investment selection. TAM does not receive any
client referrals from broker-dealers.
TAM is affiliated with Schwab as an independent advisor and therefore receives from
Schwab independent investment advisor services that include custody of securities, trade
execution, clearance, and settlement of transactions.
We do not maintain the discretionary authority to determine the broker-dealers and/or
custodians with whom orders for the purchase or sale of securities for client accounts are to
be placed or the commission rates to be charged in connection with such transactions. Our
firm routinely recommends that clients direct us to execute trades through Schwab. Where
the client directs us to use a broker or dealer other than Schwab for execution of
transactions (i.e., client directed brokerage), you are advised that TAM may be unable to
achieve the most favorable execution of client transactions. Client directed brokerage may
cost clients more money than other arrangements. For example, in a directed brokerage
account, the client may pay higher brokerage commissions because TAM may be unable to
aggregate orders to reduce transaction costs or to negotiate reduced commissions, or the
client may simply receive less favorable prices for specific securities transactions.
We do not direct brokerage business to any broker in exchange for client referrals.
Block Trading. TAM uses aggregate, or “block,” trading (i.e., combining orders for multiple
clients’ accounts into a single order) when it believes one or more of its clients has a need in
the client’s asset allocation. When one or more block trades have been placed, the securities
bought or sold are allocated across client accounts based on the needs of each client’s
portfolio, consistent with the allocation percentages identified in each client’s Investment
Policy Statement.
Item 13 – Review of Accounts
All accounts are reviewed at least weekly by the firm’s principal, Michael L. Marvin, CFP®.
All accounts are further reviewed on a quarterly basis for tax-triggering dates, asset
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allocation and diversification objectives, and other factors. More frequent reviews of client
accounts may be triggered by a change in the client’s investment objectives; risk/return
profile; tax considerations; large contributions and/or withdrawals; large sales or
purchases; security specific events; or changes in the economy more generally.
limits the total number of clients to ensure
Mr. Marvin contacts clients by telephone, regular mail or electronic mail no less frequently
than once per quarter. Most clients are contacted on a more frequent basis with updates on
their accounts and on progress toward their short- and long-term goals and objectives.
Clients are always welcome to contact TAM with questions, concerns or other feedback.
TAM
frequent and personalized
communications with all of its clients.
Item 14 – Client Referrals and Other Compensation
TAM does not compensate, nor does it receive compensation, for client referrals to or from
any other individual or company.
As disclosed under Item 12 above, TAM is affiliated with Schwab as an independent
advisor. TAM may recommend Schwab to clients for custody and brokerage services. There
is no direct link between our affiliation with Schwab and the investment advice we give to our
clients, although TAM receives economic benefits through its affiliation with Schwab that
are typically not available to Schwab retail investors. These benefits include the following
products and services (provided without cost or at a discount): receipt of duplicate client
statements and confirmations; research related products and tools; consulting services;
access to a trading desk serving Advisor participants; access to block trading (which
provides the ability to aggregate securities transactions for execution and then allocate the
appropriate shares to client accounts); the ability to have advisory fees deducted directly
from client accounts; access to an electronic communications network for client order
entry and account information; and access to mutual funds with no transaction fees and to
certain institutional money managers.
Some of the products and services made available by Schwab may benefit us but may not
benefit our client accounts. These products or services may assist us in managing and
administering client accounts, including accounts not maintained at Schwab. Other services
made available by Schwab are intended to help TAM further develop its business
enterprise. The benefits received by TAM or its personnel through its affiliation with
Schwab do not depend on the amount of brokerage transactions directed to Schwab. As
part of its fiduciary duties to clients, TAM endeavors at all times to put the interests of its
clients first.
Clients should be aware, however, that the receipt of economic benefits by TAM or its related
persons in and of itself creates a potential conflict of interest and may indirectly influence
our recommendation of Schwab for custody and brokerage services.
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Item 15 – Custody
Other than having the ability to deduct advisory fees from client accounts or to transfer cash
between two or more of a client’s accounts held at Schwab or another custodian via a
Standing Letter of Authorization (SLOA), TAM does not have custody of client funds or
securities and shall have no liability to the client for any loss or other harm to any property
in the account. This includes any harm to any property in the account resulting from the
insolvency of Schwab (or any other custodian) or any acts of the agents or employees of the
custodian, whether or not the full amount or such loss is covered by the SIPC or any other
insurance which may be carried by the custodian. Clients understand that SIPC provides
only limited protection for the loss of property held by a broker-dealer.
Clients should receive at least quarterly statements from the custodian that holds and
maintains the client’s assets. TAM urges you to carefully review such statements and
compare such official custodial records to the account statements that we may provide to
you. Our statements may vary from custodial statements based on accounting procedures,
reporting dates, or valuation methodologies of certain securities. Clients should always rely
on the account statements provided by the custodian for the most accurate valuation of their
account. Please contact us immediately if you have any questions about the account
statements provided by our firm or the Custodian.
Item 16 – Investment Discretion
TAM usually receives discretionary authority from the client at the outset of an investment
management advisory relationship to select the identity, timing, and amount of securities to
be bought or sold for the client’s account and risk without obtaining the specific consent of
the client for each transaction. Financial planning and pension consulting engagements are
non-discretionary in nature, meaning the client retains sole authority to accept or reject any
of our financial or retirement planning recommendations and to determine the manner,
timing, and service providers to be used in implementing any of the same. Clients are not
obligated to engage TAM for implementation of any financial planning or retirement
planning advice.
When selecting and recommending securities and the amounts of securities to be bought or
sold, TAM observes the investment policies, limitations and restrictions of the clients for
which it advises. For registered investment companies, TAM’s authority to trade securities
may also be limited by certain federal securities and tax laws that require diversification of
investments and favor the holding of investments once made.
Your investment guidelines and restrictions must be provided to TAM in writing. Limits on
purchases and amounts are agreed upon with clients and confirmed on at least an annual
basis.
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Item 17 – Voting Client Securities
As a matter of firm policy and practice, TAM does not have any authority to and does not vote
proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting
proxies for any and all securities maintained in client portfolios.
TAM may provide advice to clients regarding the clients’ voting of proxies upon request. TAM
clients will receive their proxies or other solicitations directly from their custodian or
transfer agent.
Item 18 – Financial Information
Registered investment advisors are required in this Item to provide you with certain
financial information or disclosures about TAM’s financial condition.
TAM does not require or solicit prepayment of more than $1,200 in fees per client, six months
or more in advance and has no financial commitment or condition that impairs its ability to
meet contractual and fiduciary commitments to clients.
TAM has never been the subject of a bankruptcy proceeding.
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