Overview

Assets Under Management: $294 million
Headquarters: STAMFORD, CT
High-Net-Worth Clients: 2
Average Client Assets: $104 million

Services Offered

Services: Portfolio Management for Individuals, Portfolio Management for Institutional Clients

Clients

Number of High-Net-Worth Clients: 2
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 70.99
Average High-Net-Worth Client Assets: $104 million
Total Client Accounts: 194
Discretionary Accounts: 194

Regulatory Filings

CRD Number: 150200
Filing ID: 1976397
Last Filing Date: 2025-04-03 16:50:00
Website: https://tjtcapital.com

Form ADV Documents

Additional Brochure: 2025 TJT CAPITAL ADV PART 2A (2025-04-03)

View Document Text
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. TJT Capital Group, LLC Page 1 March 17, 2025 FORM ADV PART 2A - BROCHURE 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. TJT Capital Group, LLC Page 2 March 17, 2025 FORM ADV PART 2A - BROCHURE 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 TJT Capital Group, LLC Page 3 March 17, 2025 FORM ADV PART 2A - BROCHURE 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. TJT Capital Group, LLC Page 4 March 17, 2025 FORM ADV PART 2A - BROCHURE 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: TJT Capital Group, LLC Page 5 March 17, 2025 FORM ADV PART 2A - BROCHURE 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 TJT Capital Group, LLC Page 6 March 17, 2025 FORM ADV PART 2A - BROCHURE 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 TJT Capital Group, LLC Page 7 March 17, 2025 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 TJT Capital Group, LLC Page 8 March 17, 2025 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. TJT Capital Group, LLC Page 9 March 17, 2025 FORM ADV PART 2A - BROCHURE 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 TJT Capital Group, LLC Page 10 March 17, 2025 FORM ADV PART 2A - BROCHURE 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 TJT Capital Group, LLC Page 11 March 17, 2025 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. TJT Capital Group, LLC Page 13 March 17, 2025 FORM ADV PART 2A - BROCHURE 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. TJT Capital Group, LLC Page 14 March 17, 2025 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. TJT Capital Group, LLC Page 15 March 17, 2025 FORM ADV PART 2A - BROCHURE

Primary Brochure: 2025 TJT CAPTIAL - ADV PART 2B (2025-04-03)

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TJT Capital Group, LLC FORM ADV PART 2B - BROCHURE SUPPLEMENT 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 supplement provides informa(cid:415)on about key personnel of TJT Capital Group that supplements the TJT Capital Group, LLC brochure. You should have received a copy of that brochure. Please contact Kevin Duffy if you did not receive TJT Capital Group’s brochure or if you have any ques(cid:415)ons about the contents of this supplement. Addi(cid:415)onal informa(cid:415)on about our personnel is available on the SEC’s website at www.adviserinfo.sec.gov. TJT Capital Group, LLC Page 1 March 17, 2025 FORM ADV PART 2B - BROCHURE Item 2: Educa(cid:415)onal Background and Business Experience Timothy McMullan, born in 1961, has more than 35 years of experience in the investment management business. Prior to being a founding partner in TJT Capital Group, Tim was Senior Vice President of the Private Client Group of GE Private Asset Management, Inc., a unit of General Electric. From July 2004 un(cid:415)l the founding of TJT Capital Group, Tim was responsible for the overall growth and profitability of the billion-dollar money management group, as well as day-to-day opera(cid:415)ons and management of the team. Tim started his career at Merrill Lynch, spending eight years in the Park Avenue office in New York City as a Vice President. A(cid:332)er Merrill Lynch, Tim moved to Paine Webber (now part of UBS) as a Vice President and por(cid:414)olio manager in Stamford, CT. Tim graduated from Colgate University with a B.A. in Economics. , born in 1974, has more than 25 years in the investment management industry. Prior to James Cook, becoming a founding partner in TJT Capital Group, Jim was a Vice President and Senior Account Execu(cid:415)ve with the Private Client Group of GE Private Asset Management, Inc., and its predecessor. Jim held a leadership posi(cid:415)on in the Private Client Group with a focus on account management. Jim received a Bachelor’s degree from SUNY Cortland in 1996 and an M.B.A. in Financial Management from Pace University’s Lubin School of Business in 2001. He earned his CERTIFIED FINANCIAL PLANNER™ cer(cid:415)fica(cid:415)on in 2008. CERTIFIED FINANCIAL PLANNER™, CFP® Cer(cid:415)fied Financial Planner Board of Standards, Inc. (CFP Board) owns the CFP® cer(cid:415)fica(cid:415)on mark, the CERTIFIED FINANCIAL PLANNER™ cer(cid:415)fica(cid:415)on mark, and the CFP® cer(cid:415)fica(cid:415)on mark (with plaque design) logo in the United States, which it authorizes use of by individuals who successfully complete CFP Board’s ini(cid:415)al and ongoing cer(cid:415)fica(cid:415)on requirements. The CFP® cer(cid:415)fica(cid:415)on is a voluntary cer(cid:415)fica(cid:415)on; no federal or state law or regula(cid:415)on requires financial planners to hold CFP® cer(cid:415)fica(cid:415)on. It is recognized in the United States and a number of other countries for its (1) high standard of professional educa(cid:415)on; (2) stringent code of conduct and standards of prac(cid:415)ce; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 95,000 individuals have obtained CFP® cer(cid:415)fica(cid:415)on in the United States. To a(cid:425)ain the right to use the CFP® marks, an individual must sa(cid:415)sfactorily fulfill the following requirements: • • Educa(cid:415)on – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and a(cid:425)ain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, re(cid:415)rement planning, and estate planning; Examina(cid:415)on – Pass the comprehensive CFP® Cer(cid:415)fica(cid:415)on Examina(cid:415)on. The examina(cid:415)on, administered in 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s TJT Capital Group, LLC Page 2 March 17, 2025 FORM ADV PART 2B - BROCHURE • • ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; Experience – Complete at least three years of full-(cid:415)me financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and prac(cid:415)ce standards for CFP® professionals. Individuals who become cer(cid:415)fied must complete the following ongoing educa(cid:415)on and ethics requirements in order to maintain the right to con(cid:415)nue to use the CFP® marks: • Con(cid:415)nuing Educa(cid:415)on – Complete 30 hours of con(cid:415)nuing educa(cid:415)on hours every two years, including • two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revoca(cid:415)on of their CFP® cer(cid:415)fica(cid:415)on. Item 3: Disciplinary Informa(cid:415)on None Item 4: Other Business Ac(cid:415)vi(cid:415)es None Item 5: Addi(cid:415)onal Compensa(cid:415)on None Item 6: Supervision Kevin T. Duffy Jr is the firm’s Chief Compliance Officer. He is responsible for the overall supervisory review process for our firm. Mr. Duffy is an outside a(cid:425)orney who has spent over 35 years in the securi(cid:415)es business, including serving as Enforcement A(cid:425)orney for the US Securi(cid:415)es & Exchange Commission. Mr. Duffy runs his own law prac(cid:415)ce when not providing CCO services to the firm. Mr. Duffy does not provide investment advice to any of the firm’s clients. Timothy McMullan and James Cook advise clients of the firm and conduct regular reviews, which will be determined on a case-by-case basis. The factors that may trigger a review of an TJT Capital Group, LLC Page 3 March 17, 2025 FORM ADV PART 2B - BROCHURE account(s) include, but are not limited to, large scale market fluctua(cid:415)ons, the asset alloca(cid:415)on percentage levels in an account and the calendar. Addi(cid:415)onal reviews may be performed as requested by a client. Client communica(cid:415)on is tracked in the firm’s contact management system database, Advisor Engine. Generally, client phone conversa(cid:415)ons are summarized and logged and email communica(cid:415)on, both to and from the firm, are archived in the Advisor Engine database and are reviewed regularly by Kevin T. Duffy Jr. in his capacity as Chief Compliance Officer. Timothy McMullan and James Cook act as the Firm’s investment commi(cid:425)ee, reviewing the Firm’s products, trading, and fund selec(cid:415)on. Correspondence, adver(cid:415)sing, presenta(cid:415)ons, and web sites are reviewed for compliance purposes by Kevin T Duffy, Jr. Any of the individuals above can be reached at (203) 504-8850. TJT Capital Group, LLC Page 4 March 17, 2025 FORM ADV PART 2B - BROCHURE