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Item 1: Cover Page
TJT Capital Group, LLC
FORM ADV PART 2A - BROCHURE
March 17, 2025
9 W. Broad Street
Suite 420
Stamford, Connec(cid:415)cut 06902
Telephone: 203.504.8850
Facsimile: 203.504.8849
Email: info@tjtcapital.com
Website: www.tjtcapital.com
This brochure provides informa(cid:415)on about the qualifica(cid:415)ons and business prac(cid:415)ces of TJT
Capital Group, LLC. If you have any ques(cid:415)ons about the contents of this brochure, please
contact us at 203.504.8850. The informa(cid:415)on in this brochure has not been approved or verified
by the United States Securi(cid:415)es and Exchange Commission (SEC) or by any state securi(cid:415)es
authority.
Addi(cid:415)onal informa(cid:415)on about TJT Capital Group, LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov.
TJT Capital Group, LLC is an SEC registered investment adviser. Registra(cid:415)on with the United
States Securi(cid:415)es and Exchange Commission or any state securi(cid:415)es authority does not imply a
certain level of skill or training.
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Item 2: Material Changes
In 2023 Charles Schwab completed its integra(cid:415)on of all TD Ameritrade accounts under the Charles Schwab
name. Currently all TJT Capital Group AUM is at Charles Schwab.
There are no other material changes since our last annual update.
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Item 3: Table of 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 Compensa(cid:415)on .............................................................................................................................. 7
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 ..................................................................... 8
Item 9: Disciplinary Informa(cid:415)on .............................................................................................................................. 9
Item 10: Other Financial Industry Ac(cid:415)vi(cid:415)es and Affilia(cid:415)ons ................................................................................... 9
Item 11: Code of Ethics, Par(cid:415)cipa(cid:415)on or Interest in Client Transac(cid:415)ons and Personal Trading ............................ 10
Item 12: Brokerage Prac(cid:415)ces ................................................................................................................................. 11
Item 13: Review of Accounts ................................................................................................................................. 13
Item 14: Client Referrals and Other Compensa(cid:415)on .............................................................................................. 13
Item 15: Custody .................................................................................................................................................... 14
Item 16: Investment Discre(cid:415)on ............................................................................................................................. 14
Item 17: Vo(cid:415)ng Client Securi(cid:415)es ............................................................................................................................ 15
Item 18: Financial Informa(cid:415)on .............................................................................................................................. 15
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Item 4: Advisory Business
TJT Capital Group, LLC is an SEC registered investment adviser located in Stamford, Connec(cid:415)cut. We are
organized as a limited liability company under the laws of the state of Delaware. Timothy McMullan and
James A. Cook are the Managing Members and Principal Owners of TJT Capital Group, LLC. TJT Capital Group,
LLC has been providing investment advisory services since 2009. We offer the following investment advisory
services, which are tailored to meet the needs of each individual client:
• Por(cid:414)olio Management services for individuals and/or small businesses
• Por(cid:414)olio Management services for businesses or ins(cid:415)tu(cid:415)onal clients (other than investment
companies)
The following paragraphs describe our investment advisory services. Please refer to the descrip(cid:415)on of each
investment advisory service listed below for informa(cid:415)on on how we tailor our advisory services to your
individual needs. Throughout this brochure, the words “we”, “our” and “us” refer to TJT Capital Group, LLC and
the words “you”, “your” and “client” refer to you as either a client or prospec(cid:415)ve client of our firm. Also, you
may see the term Associated Person throughout this brochure. As used in this brochure, our Associated
Persons are our firm’s officers, employees, and all individuals providing investment advice on behalf of our
firm.
Por(cid:414)olio Management Services
Directly Managed Accounts
TJT Capital Group, LLC primarily focuses on asset alloca(cid:415)on and mutual fund and exchange-traded fund (ETFs)
selec(cid:415)on for the investment management of its client accounts, on a discre(cid:415)onary basis, among our
investment objec(cid:415)ve categories. The alloca(cid:415)on and selec(cid:415)on are tailored to the client’s stated investment
goals and objec(cid:415)ves in conjunc(cid:415)on with our assessment of risk condi(cid:415)ons. We are authorized, without prior
consulta(cid:415)on or approval with a client, to buy, sell, trade and allocate in and among stocks, bonds, ETFs, mutual
funds, sub-advisers, independent investment managers and/or programs (with or without discre(cid:415)on,
depending upon the independent investment manager or program) and other securi(cid:415)es and/or contracts
rela(cid:415)ng to the same, on margin (only if wri(cid:425)en authoriza(cid:415)on has been granted) or otherwise, and to give
instruc(cid:415)ons in furtherance of such authority to the registered broker-dealer and the custodian of the assets.
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We provide investment management services where the investment strategy and advice is tailored in an
a(cid:425)empt to meet the needs of the client’s designated investment goals and objec(cid:415)ves. Unless the client has
advised us to the contrary, in wri(cid:415)ng, there are no restric(cid:415)ons that the client has imposed upon the adviser
with respect to the management of the assets. At the opening of an account, TJT Capital Group, LLC, through
its designated representa(cid:415)ves, shall obtain informa(cid:415)on from the client which is sufficient to determine the
client’s financial situa(cid:415)on and investment objec(cid:415)ves. The client’s account is managed on the basis of the
client’s financial situa(cid:415)on and investment objec(cid:415)ves in conjunc(cid:415)on with our assessment of risk condi(cid:415)ons. At
least quarterly, TJT Capital Group, LLC shall no(cid:415)fy the client to advise TJT Capital Group, LLC whether the
client’s financial situa(cid:415)on or investment objec(cid:415)ves have changed, or if the client wants to impose and/or
modify any reasonable restric(cid:415)ons on the management of his/her/its account. At least annually, TJT Capital
Group, LLC shall contact the client to determine whether the client’s financial situa(cid:415)on or investment
objec(cid:415)ves have changed, or if the client wants to impose and/or modify any reasonable restric(cid:415)ons on the
management of his/her/its account(s). TJT Capital Group, LLC shall be reasonably available to consult with the
client rela(cid:415)ve to the status of the client’s account.
Independent Managers
We may allocate (and/or recommend that the client allocate) a por(cid:415)on of a client’s investment assets among
unaffiliated independent investment managers in accordance with the client’s designated investment
objec(cid:415)ves. In such situa(cid:415)ons, the Independent Manager[s] shall have day-to-day responsibility for the ac(cid:415)ve
discre(cid:415)onary management of the allocated assets. TJT Capital Group, LLC shall con(cid:415)nue to render investment
supervisory services to the client related to the ongoing monitoring and review of account performance, asset
alloca(cid:415)on and client investment objec(cid:415)ves. Factors which TJT Capital Group, LLC shall consider in
recommending Independent Manager[s] include the client’s designated investment objec(cid:415)ves, management
style, performance, reputa(cid:415)on, financial strength, repor(cid:415)ng, pricing, and research.
Client Obliga(cid:415)ons
The client agrees to promptly provide informa(cid:415)on and/or documenta(cid:415)on requested by the adviser as it
pertains to client’s objec(cid:415)ves, needs and goals, and maintains exclusive responsibility to keep the adviser
informed of any changes. The adviser shall not be required to verify any informa(cid:415)on obtained from the client,
the client’s a(cid:425)orney, accountant or other professionals, and is expressly authorized to rely thereon.
Non-Investment Consul(cid:415)ng/Implementa(cid:415)on Services
TJT Capital Group, LLC does not hold itself out as providing financial planning, estate planning, or insurance
planning services. If requested by the client, we may provide limited advice regarding non-investment related
ma(cid:425)ers. We are not an a(cid:425)orney, accountant or insurance agent, and no por(cid:415)on of our services should be
construed as such. To the extent requested by a client, we may recommend the services of other professionals
for certain non-investment implementa(cid:415)on purposes (i.e., a(cid:425)orneys, accountants, insurance, etc.). The client is
under no obliga(cid:415)on to engage the services of any such recommended professional. The client retains absolute
discre(cid:415)on over all such implementa(cid:415)on.
TJT CAPITAL GROUP, LLC INVESTMENT OBJECTIVE CATEGORIES
TJT Capital Group, LLC offers the following four general investment objec(cid:415)ve categories:
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Aggressive Growth: This investment objec(cid:415)ve category is best suited for aggressive long-term investors willing
to accept higher vola(cid:415)lity in the pursuit of poten(cid:415)ally higher returns over a full market cycle. The focus is on
using open-end mutual funds, closed-end mutual funds, exchange traded funds (ETFs), and individual equi(cid:415)es
with risk/return characteris(cid:415)cs that, in the opinion of management, have the poten(cid:415)al to meet the objec(cid:415)ves.
Funds may include domes(cid:415)c, interna(cid:415)onal and emerging market equi(cid:415)es and fixed-income securi(cid:415)es, currency
and commodity funds.
Growth: This investment objec(cid:415)ve category is suited for investors with a long-term investment (cid:415)me horizon
willing to tolerate above average risk and vola(cid:415)lity with the goal of achieving above-average growth of
principal. The focus is on using open-end mutual funds, closed-end mutual funds, ETFs, and individual equi(cid:415)es
that invest in domes(cid:415)c large-, mid- and small-capitalized securi(cid:415)es, interna(cid:415)onal funds (including developed
and emerging markets), fixed-income, and currency and commodity funds.
Balanced: This investment objec(cid:415)ve category is designed with a combina(cid:415)on of equity and fixed-income
securi(cid:415)es providing the poten(cid:415)al for growth of a por(cid:415)on of the capital over (cid:415)me, with a commensurate
alloca(cid:415)on to fixed-income securi(cid:415)es to provide a current income stream. The focus is on using open-end
mutual funds, closed-end mutual funds, ETFs, individual equi(cid:415)es, and government securi(cid:415)es. Although at a
neutral weigh(cid:415)ng the equity and fixed-income por(cid:415)on will approximate 50% each, changing market condi(cid:415)ons
and our assessment of risk condi(cid:415)ons could cause those percentages to differ materially.
Income: This investment objec(cid:415)ve category is designed for those seeking above-average incomes from
government, corporate and municipal securi(cid:415)es, with the goal of being more tac(cid:415)cal and opportunis(cid:415)c in
taking advantage of market condi(cid:415)ons. The focus is on using open-end mutual funds, closed-end mutual
funds, ETFs, and government securi(cid:415)es. Equity, Real Estate Investment Trust (REIT), and u(cid:415)lity funds may also
be used from (cid:415)me to (cid:415)me. The expecta(cid:415)on for higher income over a full market cycle will be accompanied by
a higher risk profile.
Please note that there can be no assurance that the above investment category objec(cid:415)ves will be met.
Types of Investments
TJT Capital Group, LLC primarily focuses on the asset alloca(cid:415)on and mutual fund and exchange-traded fund
(ETFs) selec(cid:415)on, on a discre(cid:415)onary basis, in accordance with the client’s designated investment objec(cid:415)ves and
goals in conjunc(cid:415)on with our assessment of risk condi(cid:415)ons. We may also provide advice on any type of
investment held in your por(cid:414)olio at the incep(cid:415)on of our advisory rela(cid:415)onship. You may request, within reason
that we refrain from inves(cid:415)ng in par(cid:415)cular securi(cid:415)es or certain types of securi(cid:415)es, including restric(cid:415)ng
purchases of certain mutual funds. You must provide these restric(cid:415)ons to our firm in wri(cid:415)ng.
Assets Under Management
As of March 27, 2025, our client assets under management (AUM) were as follows:
• Discre(cid:415)onary client AUM: $274,061,000.00
• Non-Discre(cid:415)onary client AUM: $0.00
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Item 5: Fees and Compensa(cid:415)on
Our annual investment advisory fee shall be based upon a percentage (%) of the market value of the account
assets placed under our management (between 1.50% and 0.40%), as set forth below:
Income Based Por(cid:414)olios
Assets Under Management Annualized Fee Rate
Assets up to $499,999 0.50%
Assets between $500,000 - $999,999 0.45%
Assets in excess of $1,000,000 0.40%
Equity Based Por(cid:414)olios
Assets Under Management Annualized Fee Rate
Assets up to $499,999 1.50%
Assets between $500,000 - $749,999 1.25%
Assets between $750,000 - $999,999 1.125%
Assets between $1,000,000 - $1,999,999 1.00%
Assets in excess of $2,000,000 0.85%
Our annual investment advisory fee shall be paid quarterly, in advance, based upon the market value of the
account assets on the last business day of the previous quarter. Our fees will be prorated in the event the
investment advisory agreement is executed at any (cid:415)me other than the first day of a calendar quarter. We will
either invoice you directly or as paying agent for our firm, your independent custodian will directly debit your
account(s) for the payment of our investment advisory fee(s). No increase in the fee percentage shall be
effec(cid:415)ve without prior wri(cid:425)en no(cid:415)fica(cid:415)on to the client.
We generally require a minimum account balance of $100,000. We may, in our sole discre(cid:415)on, waive or reduce
the minimum balance requirement. Addi(cid:415)onally, we may, in our sole discre(cid:415)on, charge a lesser investment
advisory fee based upon certain criteria, for example, an(cid:415)cipated future earning capacity, an(cid:415)cipated future
addi(cid:415)onal assets, dollar amount of assets to be managed, related accounts, account composi(cid:415)on, or
nego(cid:415)a(cid:415)ons with the client.
Termina(cid:415)on of the Agreement
The management fee will be pro-rated for the quarter in which the wri(cid:425)en termina(cid:415)on no(cid:415)ce was received (e-
mail no(cid:415)ce will not suffice) and any unearned fees will be refunded to you.
Addi(cid:415)onal Fees and Expenses
As part of our investment advisory services to you, we may invest or recommend that you invest in mutual
funds and ETFs. The fees that you pay to our firm for investment advisory services are separate and dis(cid:415)nct
from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund’s
prospectus) to their shareholders. These fees will generally include a management fee and other fund
expenses. You may also incur transac(cid:415)on charges and/or brokerage fees when purchasing or selling securi(cid:415)es.
We primarily use no-load mutual funds, but some no-load mutual funds may involve a transac(cid:415)on fee. These
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FORM ADV PART 2A - BROCHURE
charges and fees are typically imposed by the broker-dealer or custodian through whom your account
transac(cid:415)ons are executed. We do not share in any por(cid:415)on of the brokerage fees/transac(cid:415)on charges imposed
by the broker-dealer or custodian. To fully understand the total cost you will incur, you should review all the
fees charged by mutual funds, exchange traded funds, the custodian, our firm, and by others. For more
informa(cid:415)on regarding brokerage prac(cid:415)ces, please refer to the “Brokerage Prac(cid:415)ces” sec(cid:415)on of this brochure.
Item 6: Performance-Based Fees and Side-By-Side Management
We do not accept performance-based fees or par(cid:415)cipate in side-by-side management.
Item 7: Types of Clients
We offer investment advisory services to individuals, high net worth individuals, pension and profit-sharing
plans, trusts, estates, charitable organiza(cid:415)ons, corpora(cid:415)ons, and other business en(cid:415)(cid:415)es. In general, we
require a minimum account balance of $100,000.00. TJT Capital Group, in its sole discre(cid:415)on, may waive or
reduce its minimum account balance requirement.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies
TJT Capital Group, LLC uses a combina(cid:415)on of fundamental, technical, and cyclical methods to determine asset
alloca(cid:415)on and fund selec(cid:415)on in client accounts. The main sources of informa(cid:415)on include The Federal Reserve,
Government Agencies, prospectuses, financial newspapers, magazines, websites and research materials
prepared by others. From (cid:415)me to (cid:415)me, TJT Capital Group, LLC will meet with por(cid:414)olio managers of mutual
funds in order to get further insight into their inves(cid:415)ng process. All investment strategies and funds used have
the poten(cid:415)al for risk of loss, and losses can equal that of an investor’s invested capital.
TJT Capital Group primarily u(cid:415)lizes mutual funds and exchange traded funds (ETFs), however, we may u(cid:415)lize
other types of investments such as stocks, bonds, etc., based on a client’s stated goals and objec(cid:415)ves. Mutual
funds and exchange-traded funds (ETFs) are investment vehicles that are made up of a pool of funds collected
from many investors for the purpose of inves(cid:415)ng in securi(cid:415)es such as stocks, bonds, money market
instruments and similar assets. Mutual funds and exchange traded funds (ETFs) are operated by money
managers, who invest the fund's capital and a(cid:425)empt to produce capital gains and income for the fund's
investors. Mutual funds and exchange-traded funds (ETFs) por(cid:414)olios are structured and maintained to match
the investment objec(cid:415)ves stated in its prospectus. Mutual funds and exchange-traded funds (ETFs) also come
with some risks, including but not limited to the following:
• Credit Risk
• Call Risk
• Principal Risk
• Prepayment Risk
• Market Risk
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FORM ADV PART 2A - BROCHURE
• Country Risk
•
Infla(cid:415)on Risk
• Manager Risk
• Currency Risk
Our strategies and investments may have unique and significant tax implica(cid:415)ons. However, unless we
specifically agree otherwise, and in wri(cid:415)ng, tax efficiency is not our primary considera(cid:415)on in the management
of your assets. Regardless of your account size or any other factors, we strongly recommend that you regularly
consult with a tax professional prior to and throughout the inves(cid:415)ng of your assets.
As a result of revised IRS regula(cid:415)ons, custodians and broker-dealers began repor(cid:415)ng the cost basis of equi(cid:415)es
acquired in client accounts on or a(cid:332)er January 1, 2011. Your custodian will default to the FIFO (First In First
Out) accoun(cid:415)ng method for calcula(cid:415)ng the cost basis of your investments. You are responsible for contac(cid:415)ng
your tax advisor to determine if this accoun(cid:415)ng method is the appropriate choice for you. If your tax advisor
believes another accoun(cid:415)ng method is more advantageous, please provide wri(cid:425)en no(cid:415)ce to our firm
immediately and we will no(cid:415)fy your account custodian of your individually selected accoun(cid:415)ng method.
Please note that decisions regarding the designa(cid:415)on of cost basis accoun(cid:415)ng methods will need to be made
before the trade(s) se(cid:425)les, as the cost basis method cannot be changed a(cid:332)er the trade se(cid:425)lement date.
Investment Risk
Different types of investments involve varying degrees of risk, therefore, inves(cid:415)ng in securi(cid:415)es involves a risk of
loss that you should be prepared to bear. TJT Capital Group, LLC does not guarantee the future performance of
an account or any specific level of performance, the success of any investment recommenda(cid:415)on or strategy
that we may take or recommend for the account, or the success of our overall management of the account.
The investment recommenda(cid:415)on for the account made by TJT Capital Group, LLC are subject to various
market, currency, economic, poli(cid:415)cal, and business risks, and that those investment decisions will not always
be profitable. Past performance is in no way an indica(cid:415)on of future performance.
Item 9: Disciplinary Informa(cid:415)on
Neither our firm nor any of our Management Persons or Principals has any reportable disciplinary informa(cid:415)on.
Item 10: Other Financial Industry Ac(cid:415)vi(cid:415)es and Affilia(cid:415)ons
Recommenda(cid:415)on of Other Advisers
TJT Capital Group, LLC has entered into a por(cid:414)olio consul(cid:415)ng agreement with Carlson Wealth Advisors, LLC
(CWA). CWA will receive compensa(cid:415)on from TJT Capital Group, LLC for those accounts on which CWA is
consulted. You are not obligated, contractually or otherwise, to use the services of CWA.
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Business Access Line of Credit
TJT Capital Group, LLC has a Business Access Line of Credit at M&T Bank in the amount of $250,000.00. This is
a discre(cid:415)onary line of credit due on demand. The credit line is secured by a first-person lien on the business
assets of TJT Capital Group, LLC, and is personally guaranteed by Timothy McMullan and James Cook. The
balance on this Line of Credit has the ability to change daily. TJT Capital Group, LLC has a zero-balance due on
this Line of Credit as of March 17, 2025.
Item 11: Code of Ethics, Par(cid:415)cipa(cid:415)on or Interest in Client Transac(cid:415)ons and
Personal Trading
Descrip(cid:415)on of Our Code of Ethics
TJT Capital Group, LLC Code of Ethics includes guidelines for professional business conduct standards for our
Associated Persons. Our goal is to con(cid:415)nuously protect your interests at all (cid:415)mes and to demonstrate our
commitment to our fiduciary du(cid:415)es while dealing with you. All of our Associated Persons are expected to
strictly adhere to these guidelines. Our Code of Ethics also requires that certain persons associated with our
firm submit reports of their personal account holdings and transac(cid:415)ons to a qualified representa(cid:415)ve of our
firm who will review these reports on a periodic basis. Persons associated with our firm are also required to
report any viola(cid:415)ons of our Code of Ethics policy to Kevin T. Duffy Jr., the firm’s Chief Compliance Officer. In
addi(cid:415)on, we maintain and enforce our wri(cid:425)en policies and procedures, which are reasonably designed to
prevent the
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misuse of material, non-public informa(cid:415)on about you or your account holdings by Associated Persons of our
firm.
Clients or prospec(cid:415)ve clients may obtain a copy of our Code of Ethics by contac(cid:415)ng us at the telephone
number listed on the cover page of this brochure.
Par(cid:415)cipa(cid:415)on or Interest in Client Transac(cid:415)ons
Neither TJT Capital Group, LLC or any Associated Persons of our firm has any material financial interest in client
transac(cid:415)ons beyond the condi(cid:415)on of agreement of investment advisory services as disclosed in this brochure.
Personal Trading Prac(cid:415)ces
Associated Persons of TJT Capital Group, LLC can buy or sell the same securi(cid:415)es that we recommend to you or
securi(cid:415)es in which you are already invested in. A conflict of interest could poten(cid:415)ally exist because we may
have the ability to trade ahead of you and could poten(cid:415)ally receive a more favorable price than you would
receive. To eliminate this poten(cid:415)al conflict of interest, it is our policy that Associated Persons of TJT Capital
Group, LLC shall not have priority over your account in the purchase or sale of securi(cid:415)es.
Item 12: Brokerage Prac(cid:415)ces
TJT Capital Group, LLC does not maintain custody of your assets on which we advise (although we may be deemed to
have custody of your assets if you give us authority to withdraw assets from your account (see item 15 Custody, below).
Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. TJT Capital
Group, LLC is independently owned and operated and is not affiliated with any “qualified custodian.” TJT Capital Group,
LLC recommends a custodian/broker who will hold your assets and execute transac(cid:415)ons on terms that are, overall, most
advantageous when compared to other available providers and their services. We consider a wide range of factors,
including, among others:
• Combina(cid:415)on of transac(cid:415)on execu(cid:415)on services and asset custody services (generally without a separate
fee for custody)
• Capability to execute, clear, and se(cid:425)le trades (buy and sell securi(cid:415)es for your account)
• Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill
payment, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, ETFs, etc.)
• Availability of investment research and tools that assist us in making investment decisions • Quality of
services
• Compe(cid:415)(cid:415)veness of the price of those services (commission rates, margin interest rates, other fees,
etc.) and willingness to nego(cid:415)ate the prices
• Reputa(cid:415)on, financial strength, and stability
• Prior service to us and our other clients
• Availability of other products and services that benefit us, as discussed below
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FORM ADV PART 2A - BROCHURE
Based on the above criteria, we generally recommend that our clients use the following unaffiliated, qualified
custodian for execu(cid:415)on and/or custodial services (exclusive of those clients that may direct TJT Capital Group,
LLC to use a specific broker-dealer/custodian):
• Schwab Advisor Services, Division of Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer,
member SIPC
We are not affiliated with Schwab and are independently owned and operated. Schwab provides us access to
their ins(cid:415)tu(cid:415)onal brokerage trading, custody, repor(cid:415)ng, and related services, many of which are not typically
available to retail investors. Some of those services help us manage or administer our clients’ accounts; while
others help us manage and grow our business. Schwab’s support services generally are available on an
unsolicited basis (we do not have to request them) and at no charge to us.
Schwab generally does not charge client accounts separately for custody. Schwab is generally compensated by
account holders through commissions or other transac(cid:415)on-related fees for securi(cid:415)es trades that are executed
or se(cid:425)led by Schwab. Certain trades (for example, many mutual funds, and U.S. exchange-listed equi(cid:415)es and
ETFs) may not incur Schwab commissions or transac(cid:415)on fees. Schwab is also compensated by earning interest
on the uninvested cash in your account in Schwab’s Cash Feature Program.
Schwab also makes available to us other products and services that benefit our firm but may not benefit our
client accounts. Some of these other products and services assist us in managing and administering client
accounts. These products and services include so(cid:332)ware and other technology that: provide access to client
account data (such as trade confirma(cid:415)ons and account statements); facilitate trade execu(cid:415)on; provide
research, pricing informa(cid:415)on, and other market data; facilitate payment of our investment advisory fees from
client accounts; and provide assistance with back-office func(cid:415)ons, recordkeeping, and client repor(cid:415)ng.
Generally, many of these services may be used to service all or a substan(cid:415)al number of our client accounts,
including accounts not maintained at Schwab. Schwab also makes available to us other services intended to
help us manage and grow our business. These services may include consul(cid:415)ng, publica(cid:415)ons and conferences
on prac(cid:415)ce management, legal, informa(cid:415)on technology, business succession, regulatory compliance, and
marke(cid:415)ng. In addi(cid:415)on, Schwab may make available, arrange, and/or pay for these types of services rendered
to us by independent third par(cid:415)es. Schwab may discount or waive fees it would otherwise charge for some of
these services or pay all or a part of the fees of a third party providing these services to us. As a fiduciary, we
endeavor to act in the best interests of our clients. However, our recommenda(cid:415)on that clients maintain their
assets in accounts at Schwab may be based in part on benefits provided to our firm by the availability of some
of the foregoing products and services and not solely on the nature, cost, or quality of custody and brokerage
services provided by Schwab, which can create a poten(cid:415)al conflict of interest.
Directed Brokerage
The client may direct TJT Capital Group, LLC to use a par(cid:415)cular broker-dealer (subject to TJT Capital Group, LLC
right to decline and/or terminate the engagement) to execute some or all transac(cid:415)ons for the client's account.
In such event, the client will nego(cid:415)ate terms and arrangements for the account with that broker-dealer, and
we will not seek be(cid:425)er execu(cid:415)on services or prices from other broker-dealers or be able to "batch" the client's
transac(cid:415)ons for execu(cid:415)on through other broker-dealers with orders for other accounts managed by us. As a
TJT Capital Group, LLC Page 12 March 17, 2025
FORM ADV PART 2A - BROCHURE
result, client may pay higher commissions or other transac(cid:415)on costs or greater spreads, or receive less
favorable net prices, on transac(cid:415)ons for the account than would otherwise be the case.
In the event that the client directs TJT Capital Group, LLC to effect securi(cid:415)es transac(cid:415)ons for the client's
accounts through a specific broker-dealer, the client correspondingly acknowledges that such direc(cid:415)on may
cause the accounts to incur higher commissions or transac(cid:415)on costs than the accounts would otherwise incur
had the client determined to effect account transac(cid:415)ons through alterna(cid:415)ve clearing or custodial
arrangements that may be available through TJT Capital Group, LLC.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for any form of compensa(cid:415)on.
Item 13: Review of Accounts
Client accounts are monitored on an ongoing basis. Reviews of client accounts are conducted by the firm’s
principals, Timothy McMullan and James Cook, on both an individual and collabora(cid:415)ve basis. In addi(cid:415)on,
Kevin T Duffy Jr., in his role as Chief Compliance Officer, is responsible for the supervisory review process for
our firm, which includes the overall review of client accounts. The firm’s principals meet at least weekly to
review trading, markets, risk condi(cid:415)ons, and informa(cid:415)on that can have a material effect on client accounts. All
formal reviews of client accounts are memorialized and added to the client’s records. Clients are encouraged
to request an account review at any (cid:415)me.
All new clients complete an investment ques(cid:415)onnaire to assess the client’s investment objec(cid:415)ves, risk
tolerance, and to establish specific restric(cid:415)ons, if applicable. Exis(cid:415)ng clients may update their investment
ques(cid:415)onnaire, at any (cid:415)me by reques(cid:415)ng and comple(cid:415)ng a new ques(cid:415)onnaire. On a quarterly basis we
produce and deliver to clients an account holdings statement and performance reports, as well as an
assessment of risk condi(cid:415)ons. Addi(cid:415)onally, clients receive statements from the custodian holding client funds
and securi(cid:415)es at least quarterly.
Item 14: Client Referrals and Other Compensa(cid:415)on
If a client is introduced to TJT Capital Group, LLC by either an unaffiliated or an affiliated Solicitor, we may pay
that solicitor a referral fee in accordance with the requirements of Rule 206(4)-3 of the Investment Advisers
Act of 1940, and any corresponding state securi(cid:415)es law requirements. Any such referral fee shall be paid solely
from our investment advisory fee and shall not result in any addi(cid:415)onal charge to the client. If the client is
introduced to TJT Capital Group, LLC by an unaffiliated solicitor, at the (cid:415)me of the solicita(cid:415)on, the unaffiliated
solicitor shall disclose the nature of his/her/its solicitor rela(cid:415)onship, and shall provide each prospec(cid:415)ve client
with a copy of TJT Capital Group, LLC’s Form ADV Part 2A Brochure, together with a copy of the Form ADV Part
2A Brochure from the solicitor to the client disclosing the terms of the solicita(cid:415)on arrangement between TJT
Capital Group, LLC and the solicitor, including the compensa(cid:415)on to be received by the solicitor from TJT Capital
Group, LLC.
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TJT Capital Group, LLC has entered into a por(cid:414)olio consul(cid:415)ng agreement with Carlson Wealth Advisors, LLC
(CWA). CWA refers poten(cid:415)al prospects to TJT Capital Group, LLC, and if those prospects become clients of TJT
Capital Group, LLC, CWA will receive compensa(cid:415)on from TJT Capital Group, LLC based on the clients account
value. Compensa(cid:415)on paid to CWA shall be paid solely by TJT Capital Group, LLC and shall not result in any
addi(cid:415)onal charge to the client. You are not obligated, contractually or otherwise, to use the services of CWA.
Currently, TJT Capital Group, LLC does not receive any compensa(cid:415)on from any third party in connec(cid:415)on with
providing investment advice to you.
Please refer to the “Brokerage Prac(cid:415)ces” sec(cid:415)on above for disclosures on research and other benefits we
receive resul(cid:415)ng from our rela(cid:415)onship with Schwab. The availability of these benefits is not based upon us
giving par(cid:415)cular investment advice, such as buying par(cid:415)cular securi(cid:415)es for our clients.
Item 15: Custody
TJT Capital Group, LLC does not maintain physical custody of any of your funds or securi(cid:415)es. Your funds and
securi(cid:415)es will be held with a broker-dealer, or another independent, qualified custodian. Our ability to deduct
our investment advisory fees from your account(s) causes our firm to exercise custody over your funds or
securi(cid:415)es as deemed by government regula(cid:415)ons. We may invoice you directly or as paying agent for our firm,
your independent custodian will directly debit your account(s) for the payment of our advisory fee(s). You will
receive account statements from the independent, qualified custodian(s) holding your funds and securi(cid:415)es at
least quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fee(s),
if they are deducted from your account(s). You should carefully review account statements for accuracy. If you
have a ques(cid:415)on regarding your account statement or if you did not receive a statement from your custodian,
please contact us at the telephone number listed on the cover page of this brochure. We also urge you to
compare the account statements from your custodian(s) to the quarterly statements you will receive from us.
Item 16: Investment Discre(cid:415)on
Before we can buy or sell securi(cid:415)es on your behalf, you must first sign our discre(cid:415)onary investment advisory
agreement, the custodian’s power of a(cid:425)orney, and/or trading authoriza(cid:415)on forms. You may grant our firm
discre(cid:415)on over the selec(cid:415)on and amount of securi(cid:415)es to be purchased or sold for your account(s) without
obtaining your consent or approval prior to each transac(cid:415)on. You may specify investment objec(cid:415)ves,
guidelines, and/or impose, within reason, certain condi(cid:415)ons, or investment parameters for your account(s).
For example, you may request that we refrain from inves(cid:415)ng in par(cid:415)cular securi(cid:415)es or certain types of
securi(cid:415)es, or certain mutual funds. Please refer to the “Advisory Business” sec(cid:415)on in this brochure for more
informa(cid:415)on on our discre(cid:415)onary management services.
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FORM ADV PART 2A - BROCHURE
Item 17: Vo(cid:415)ng Client Securi(cid:415)es
We will not vote proxies on behalf of your advisory account(s). If you own shares of common stock or mutual
funds, you are exclusively responsible for exercising your right to vote as a shareholder. In addi(cid:415)on, the client
maintains exclusive responsibility for making all elec(cid:415)ons rela(cid:415)ve to corporate ac(cid:415)ons, mergers, acquisi(cid:415)ons,
tender offers, bankruptcy proceedings or other types of events pertaining to the client’s investment assets.
We do not offer advice or provide consulta(cid:415)on regarding corporate ac(cid:415)ons and the exercise of your proxy
vo(cid:415)ng rights.
Item 18: Financial Informa(cid:415)on
TJT Capital Group, LLC does not require or solicit prepayment of more than $1200.00 in fees per client, (6) six
or more months in advance, or take custody of client funds or securi(cid:415)es, or have a financial condi(cid:415)on that is
reasonably likely to lessen our ability to meet our commitments and obliga(cid:415)ons to you. Therefore, we are not
required to include a balance sheet for our most recent fiscal year. Finally, TJT Capital Group, LLC has not been
the subject of a bankruptcy pe(cid:415)(cid:415)on at any (cid:415)me.
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