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TL Private Wealth, LLC
Firm Brochure, March 27, 2026
ADV Part 2A
165 S. Kimball Avenue Suite 120
Southlake, TX 76092
www.tlwealth.com
This brochure provides information about the qualifications and business practices of TL
Private Wealth. If you have any questions about the contents of this brochure, please
contact us at 682-831-1048 or by email at: brad@tlwealth.com. 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.
Additional information about TL Private Wealth is also available on the SEC’s website at
www.adviserinfo.sec.gov
TL Private Wealth’s CRD number is: 167818
Registration does not imply a certain level of skill or training.
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ADV Part 2A, March 27, 2026
Item 2. Material Changes
From time to time, we may amend this firm brochure to reflect changes in our business
practices, changes in regulations and routine annual updates as required by the Securities
and Exchange Commission (“SEC”). This complete firm brochure or a summary of
material changes shall be provided to each client annually and if a material change occurs
in the business practices of TL Private Wealth, LLC (“TLPW”).
At any time, you may view the current firm brochure on-line at the SEC's Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching for our firm
name or by our CRD number 167818. You may also request a copy of this firm brochure at
any time, by contacting us at 682-831-1048.
The following changes have been made to this brochure since the last annual filing of this
brochure (dated March 28, 2025).
1. Updated Item 5. Fees and Compensation to better illustrate how our firm’s IARs
are compensated and to more clearly describe the valuation methodology for
billing purposes.
2. Updated Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss to
include information on cybersecurity risks.
3. Updated Item 12. Brokerage Practices to clarify TLPW’s policy regarding client
selection of custodian and related conflicts of interest.
4. Updated Item 12. Brokerage Practices to more thoroughly describe TLPW’s Best
Execution review practices.
5. Updated Item 15. Custody to more clearly describe the importance of reviewing
custodian statements and firm produced client reports.
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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 Compensation ............................................................................................... 7
Item 6. Performance-Based Fees and Side-by-Side Management ........................................10
Item 7. Types of Clients ........................................................................................................... 10
Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss ................................10
Item 9. Disciplinary Information ............................................................................................ 14
Item 10. Other Financial Industry Activities and Affiliations. .............................................. 15
Item 11. Code of Ethics, Participation or Interest in Client Transactions, and Personal
Trading ……………………………………………………………………………………………………………………………. 16
Item 12. Brokerage Practices ................................................................................................... 17
Item 13. Review of Accounts .................................................................................................... 19
Item 14. Client Referrals and Other Compensation ..............................................................20
Item 15. Custody ...................................................................................................................... 21
Item 16. Investment Discretion ..............................................................................................21
Item 17. Voting Client Securities ............................................................................................21
Item 18. Financial Information ............................................................................................... 22
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Item 4. Advisory Business
A. Description of the Advisory Firm
TL Private Wealth is a Limited Liability Company organized in the state of Texas.
The firm was formed in May of 2013, and the principal owners are Brad Little and
Dustin Richard Tondre.
B. Types of Advisory Services
TL Private Wealth (hereinafter “TLPW”) offers the following services to advisory
clients: Investment Supervisory Services
TLPW offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. TLPW creates an
Investment Policy Statement for each client, which outlines the client’s current
situation (income, tax levels, and risk tolerance levels) and then constructs a plan
to aid in the selection of a portfolio that matches each client’s specific situation.
Investment Supervisory Services include, but are not limited to, the following:
Investment Strategy
•
• Asset Allocation
• Risk Tolerance
• Personal Investment Policy
• Asset Selection
• Regular Portfolio Monitoring
TLPW evaluates the current investments of each client with respect to their risk
tolerance levels and time horizon. TLPW will request discretionary authority from
clients in order to select securities and execute transactions without permission
from the client prior to each transaction. Risk tolerance levels are documented in
the Investment Policy Statement, which is given to each client.
Financial Planning
Financial plans and financial planning may include, but are not limited to
investment planning, life insurance; tax planning; retirement planning; college
planning; and debt/credit planning. These services are included in the annual
investment advisory fee paid by the client.
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Services Limited to Specific Types of Investments
TLPW limits its investment advice and/or money management to mutual funds,
equities, bonds, fixed income, debt securities, ETFs, REITs, insurance products
including annuities, and government securities. TLPW may use other securities as
well to help diversify a portfolio when applicable. Additionally, TLPW may
recommend the services of third-party managers to provide investment
management on a separately managed account (SMAs). TLPW carefully reviews
and researches any SMA managers to ensure they are appropriate for each client's
goals and objectives.
Retirement Plan Rollovers and IRA Transfers
When we provide investment advice to you regarding your retirement plan
account or individual retirement account, we are fiduciaries within the meaning of
Title I of the Employee Retirement Income Security Act and/or the Internal
Revenue Code, as applicable, which are laws governing retirement accounts. We
may recommend an investor rollover retirement plan assets to an Individual
Retirement Account (IRA) managed by TLPW. As a result, TLPW may earn an
asset-based fee on those assets. This creates some conflicts with your interests, so
we operate under a special rule that requires us to act in your best interest and not
put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment
recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making
recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and
investments;
• Follow policies and procedures designed to ensure that we give advice that
is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
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C. Client Tailored Services and Client Imposed Restrictions
TLPW offers the same suite of services to all its clients. However, specific client
investment strategies and their implementation are dependent upon the client
Investment Policy Statement which outlines each client’s current situation
(income, tax levels, and risk tolerance levels) and is used to construct a client
specific plan to aid in the selection of a portfolio that matches restrictions, needs,
and targets.
Clients may impose restrictions in investing in certain securities or types of
securities in accordance with their values or beliefs. However, if the restrictions
prevent TLPW from properly servicing the client account, or if the restrictions
would require TLPW to deviate from its standard suite of services, TLPW reserves
the right to end the relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated
fee that includes management fees, transaction costs, fund expenses, and any
other administrative fees. TLPW does not participate in any wrap fee programs.
E. Amounts Under Management
As of the date of this brochure, TLPW had a total of $364,481,906 in regulatory
assets under management. Of the total regulatory assets under management,
$364,481,906 is managed on a discretionary basis while $0 is managed on a non-
discretionary basis.
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Item 5. Fees & Compensation
A. Fee Schedule
Investment Supervisory Services Fees
Total Assets Under Management
Annual Fee
Up to $1,000,000
1.35%
Next $2,000,000
0.90%
Next $2,000,000
0.70%
Next $5,000,000
0.60%
Next $10,000,000
0.50%
Above $20,000,000
Negotiable
These fees are negotiable depending upon the needs of the client and the
complexity of the situation. This may result in client relationships with differing
fee arrangements. The final client fee schedule is attached as Exhibit II of the
Investment Advisory Contract. TLPW uses the market value of assets as of the last
day of the previous calendar quarter for purposes of calculating advisory fees. Fees
are paid quarterly in advance. Clients may terminate the contract without penalty,
for a full refund, within five business days of signing the contract. Thereafter,
clients may terminate the contract with ten days’ written notice.
New client relationships and billable cash deposits of greater than $50,000 will be
assessed a prorated advisory fee based on the number of days remaining in the
quarter period. This policy will apply to relationships or deposits initiated in
between quarterly billing occurrences.
Refunds are given on a prorated basis, based on the number of days remaining in a
quarter at the point of termination. The fee refunded will be the balance of the fees
collected in advance less the daily rate* times the number of days in the quarter
remaining up to and including the day of termination. (*The daily rate is
calculated by dividing the quarterly AUM fee by the number of days in the
termination quarter).
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TLPW has implemented policies and procedures that ensure any applicable client
fee refunds are calculated and delivered on a timely basis. This process will ensure
that client refunds are issued within 30 days of the termination of the client
agreement. Refunds are issued only when the client relationship with TLPW has
been terminated.
Advisory fees are withdrawn directly from the client’s accounts with client written
authorization. In cases where advisory fees are directly deducted, TLPW is
required to a.) Obtain client authorization, and b.) Disclose that the custodian will
send quarterly invoices to the client wherein TLPW fees are itemized.
Client shall be given thirty (30) days’ prior written notice of any proposed increase
in fees.
Compensation of Supervised Persons
TL Private Wealth compensates its investment adviser representatives (“IARs”)
based, in part, on a percentage of the advisory fees generated from client accounts
they service. As a result, IARs have an incentive to encourage clients to maintain
assets under management with the firm or to increase the amount of assets
managed by the firm.
This compensation structure creates a conflict of interest, as an IAR may have an
incentive not to recommend that a client reduce assets under management,
transfer assets to another adviser, pay down debt, or pursue other financial
strategies that would reduce advisory fees.
TL Private Wealth seeks to mitigate this conflict through its fiduciary duty to act
in the client’s best interest, firm supervision of advisory recommendations, and
compliance policies designed to ensure that advice is based on each client’s
individual goals, risk tolerance, and financial circumstances. IARs are not
compensated based on commissions, the sale of specific investment products, or
transaction-based activity.
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ADV Part 2A, March 27, 2026
B. Payment of Fees
Payment of Investment Supervisory Fees
Advisory fees are withdrawn directly from the client’s accounts with client written
authorization. Fees are paid quarterly in advance.
C. Clients are Responsible for Third-Party Fees
Clients are responsible for the payment of all third-party fees (i.e., custodian fees,
brokerage fees, third-party manager fees, transaction fees, etc.). Those fees are
separate and distinct from the fees and expenses charged by TLPW. Please see
Item 12 of this brochure regarding our broker/custodian.
D. Prepayment of Fees
TLPW collects investment advisory fees in advance.
For all asset-based fees paid in advance, the fee refunded will be the balance of the
fees collected in advance less the daily rate* times the number of days in the
quarter remaining up to and including the day of termination. (*The daily rate is
calculated by dividing the quarterly AUM fee by the number of days in the
termination quarter).
E. Outside Compensation for the Sale of Securities to Clients
Neither TLPW nor its supervised persons accept any compensation for the sale of
securities or other investment products, including asset-based sales charges or
services fees from the sale of mutual funds.
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Item 6. Performance Based Fees & Side-by-Side Management
TLPW does not accept performance-based fees or other fees based on a share of
capital gains on or capital appreciation of the assets of a client.
Item 7. Types of Clients
TLPW provides investment advice and/or management supervisory services to the
following types of clients:
Individuals
•
• High-Net-Worth Individuals
Minimum Account Size
There is an account minimum of $1,000,000, which may be waived by TLPW, based
on the needs of the client and the complexity of the situation.
Item 8. Methods of Analysis, Investment Strategies, and Risk
of Investment Loss
A. Method of Analysis & Investment Strategies
Methods of Analysis
TLPW primarily utilizes fundamental and cyclical analysis when managing client
portfolios and selecting investments.
Fundamental analysis involves the analysis of financial statements, the general
financial health of companies, and/or the analysis of management or competitive
advantages.
Cyclical analysis involved the analysis of business cycles to find favorable
conditions for buying and/or selling a security.
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Investment Strategies
TLPW’s investment philosophy is based on the Strategic Asset Allocation
process. Strategic asset allocation is a portfolio strategy that involves setting
target allocations for various asset classes and rebalancing periodically. The
portfolio is rebalanced to the original allocations when they deviate from the
initial settings due to differing returns from the various assets. Our firm believes in
constructing portfolios that are cost-effective, tax-effective, diversified properly
and designed for long-term commitment to the defined client strategy.
TLPW may engage in options writing in scenarios where clients have requested the
firm execute those transactions on a non-solicited and non-discretionary basis.
TLPW does not manage client investments in margin accounts. As such, any
options transactions are limited to covered-call transactions or cash-secured put
transactions. TLPW does not engage in “short-selling” transactions. “Short-Selling”
transactions carry high degrees of risk and are typically designed for more
speculative, short-term trading strategies.
Investing in securities involves a risk of loss that you, as a client, should be
prepared to bear.
B. Material Risks Involved
Methods of Analysis
Fundamental analysis concentrates on factors that determine a company’s value
and expected future earnings. This strategy would normally encourage equity
purchases in stocks that are undervalued or priced below their perceived value.
The risk assumed is that the market will fail to reach expectations of perceived
value.
Cyclical analysis assumes that the markets react in cyclical patterns which, once
identified, can be leveraged to provide performance. The risks with this strategy
are twofold: 1) the markets do not always repeat cyclical patterns and 2) if too
many investors begin to implement this strategy, it changes the very cycles these
investors are trying to exploit.
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Cyber Threats and Risk of Loss
TL Private Wealth has implemented policies and procedures to protect the
confidentiality of sensitive client information and to prevent cyber incidents.
However, no cybersecurity program can guarantee complete protection. A
cybersecurity breach could result in unauthorized access to client information,
account disruptions, or financial loss. While TL Private Wealth maintains
safeguards and monitors service providers (including Fidelity/NFS), clients are
reminded to also maintain appropriate safeguards for their own electronic
communications and account access.
Investment Strategies
Long-term trading is designed to capture market rates of both return and risk.
Frequent trading, when done, can affect investment performance, particularly
through increased brokerage and other transaction costs and taxes. Taxable gains
can occur when investments are sold as part of the regular management of client
portfolios.
Investing in securities involves a risk of loss that you, as a client, should be
prepared to bear.
C. Risks of Specific Securities Utilized
TLPW seeks investment strategies that do not involve significant or unusual risk
beyond that of the general domestic and/or international equity markets.
However, it will utilize options writing.
The investment types listed below (leaving aside Treasury Inflation
Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or
any other government agency.
Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus
you may lose money investing in mutual funds. All mutual funds have costs that
lower investment returns. They can be of bond “fixed income” nature (lower risk)
or stock “equity” nature (mentioned above).
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Equity investment generally refers to buying shares of stocks by an individual or
firms in return for receiving a future payment of dividends and capital gains if the
value of the stock increases. There is an innate risk involved when purchasing a
stock that it may decrease in value and the investment may incur a loss.
Treasury Inflation Protected/Inflation Linked Bonds: The risk of default on
these bonds is dependent upon the U.S. Treasury defaulting (an unlikely event);
however, they carry a potential risk of losing share price value, albeit rather
minimal.
Fixed Income is an investment that provides fixed periodic payments in the
future that may involve economic risks such as inflationary risk, interest rate risk,
default risk, repayment of principal risk, etc.
Debt securities carry risks such as the possibility of default on the principal,
fluctuation in interest rates, and counterparties being unable to meet obligations.
Stocks & Exchange Traded Funds (ETF): Investing in stocks & ETFs carries the
risk of capital loss (sometimes up to a 100% loss in the case of a stock holding
bankruptcy).
REITs have specific risks including valuation due to cash flows, dividends paid in
stock rather than cash, and the payment of debt resulting in dilution of shares.
Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic
shares” not physical metal): Investing in precious metal ETFs carries the risk of
capital loss.
Long-term trading is designed to capture market rates of both return and risk.
Due to its nature, the long-term investment strategy can expose clients to various
other types of risk that will typically surface at various intervals during the time
the client owns the investments. These risks include but are not limited to
inflation (purchasing power) risk, interest rate risk, economic risk, market risk,
and political/regulatory risk.
Short-term trading risks include liquidity, economic stability and inflation.
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Options writing involves a contract to purchase a security at a given price, not
necessarily at market value, depending on the market. This strategy includes the
risk that an option may expire out of the money resulting in minimal or no value
and the possibility of leveraged loss of trading capital due to the leveraged nature
of stock options. Spread option positions entail buying and selling multiple
options on the same underlying security, but with different strike prices or
expiration dates, which helps limit the risk of other option trading strategies.
Option writing also involves risks including but not limited to economic risk,
market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation
(purchasing power) risk and interest rate risk.
TLPW does not manage client investments in margin accounts. As such, any
options transactions are limited to covered-call transactions or cash-secured put
transactions. TLPW does not engage in “short-selling” transactions. “Short-Selling”
transactions carry high degrees of risk and are typically designed for more
speculative, short-term trading strategies.
Past performance is not a guarantee of future returns. Investing in
securities involves a risk of loss that you, as a client, should be prepared to
bear.
Item 9. Disciplinary Information
A. Criminal or Civil Actions
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
C. Self-Regulatory Organization (SRO) Proceedings
There are no SRO proceedings to report.
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Item 10. Other Financial Industry Activities & Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative
Neither TLPW nor its representatives are registered as or have pending
applications to become a broker/dealer or as representatives of a broker/dealer.
B. Registrations as a Futures Commission Merchant, Commodity Pool
Operator, or a Commodity Trading Advisor.
Neither TLPW nor its representatives are registered as or have pending
applications to become a Futures Commission Merchant, Commodity Pool
Operator, or a Commodity Trading Advisor.
C. Registration Relationships Material to this Advisory Business and
Possible Conflicts of Interests
Brad Little is a licensed insurance agent. From time to time, he will offer clients
advice or products from those activities. Clients should be aware that these
services pay a commission and involve a conflict of interest, as commissionable
products conflict with the fiduciary duties of a registered investment adviser.
TLPW always acts in the best interests of the client, including the sale of
commissionable products to advisory clients. Clients are in no way required to
implement the plan through any representative of TLPW in such an individual’s
capacity as an insurance agent.
D. Selection of Other Advisors or Managers and How This Advisor is
Compensated for Those Selections
TLPW carefully selects third-party managers based on their experience and the
best fit for the client's objectives and goals. These managers are paid based on an
agreed-upon asset-based fee detailed in a separate custodial agreement between
the client and the third- party manager.
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Item 11. Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
A. Code of Ethics
TLPW has a written Code of Ethics that covers the following areas: Prohibited
Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted
Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment,
Confidentiality, Service on a Board of Directors, Compliance Procedures,
Compliance with Laws and Regulations, Procedures and Reporting, Certification of
Compliance, Reporting Violations, Compliance Officer Duties, Training and
Education, Recordkeeping, Annual Review, and Sanctions. Our Code of Ethics is
available free upon request to any client or prospective client.
B. Recommendations Involving Material Financial Interests
TLPW does not recommend that clients buy or sell any security in which a related
person to TLPW or TLPW has a material financial interest.
C. Investing Personal Money in the Same Securities as Clients
From time to time, representatives of TLPW may buy or sell securities for
themselves that they also recommend to clients. This may provide an opportunity
for representatives of TLPW to buy or sell the same securities before or after
recommending the same securities to clients, resulting in representatives profiting
off the recommendations they provide to clients. Such transactions create a
conflict of interest. TLPW will always document any transactions that could be
construed as material conflicts of interest and will always transact client business
before their own when similar securities are bought or sold.
D. Trading Securities At/Around the Same Time
From time to time, representatives of TLPW may buy or sell securities for
themselves at or around the same time as clients. This may provide an opportunity
for representatives of TLPW to buy or sell securities before or after recommending
securities to clients resulting in representatives profiting off the recommendations
they provide to clients. Such transactions create a conflict of interest. TLPW will
always transact client’s transactions before its own when similar securities are
being bought or sold.
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Item 12. Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
The custodian, Fidelity Institutional, a division of FMR, LLC. Member
FINRA/SIPC/NFA, was chosen based on their relatively low-cost transactions fees
and access to mutual funds and ETFs. TLPW does not charge any additional
transaction-based compensation beyond the costs imposed by the custodian.
TLPW requires that clients maintain assets with Fidelity Institutional, a division of
FMR, LLC, as a qualified custodian. Clients do not have the option to select an
alternative custodian for accounts managed by TLPW.
This requirement creates a conflict of interest, as TLPW has an incentive to
recommend and maintain client assets at Fidelity due to the operational
efficiencies, integration with TLPW’s systems, and access to certain services and
support provided by Fidelity.
While TLPW believes that Fidelity provides high-quality custodial and execution
services at competitive rates, clients should understand that they may be able to
obtain similar services from other custodians at lower or higher costs. TLPW
addresses this conflict through its fiduciary duty to act in the best interest of
clients and through its best execution review process.
1. Research and Other Soft-Dollar Benefits
TLPW has an arrangement with National Financial Services LLC, and Fidelity
Brokerage Services LLC (together with all affiliates, “Fidelity”) through which
Fidelity provides TLPW with Fidelity’s “platform” services. The platform services
include, among others, brokerage, custodial, administrative support, record
keeping, and related services that are intended to support firms like TLPW in
conducting business and in serving the best interests of their clients but that may
benefit TLPW.
TL Private Wealth LLC
Fidelity charges brokerage commissions and transaction fees for affecting certain
securities transactions (i.e., transactions fees are charged for certain no-load
mutual funds, commissions are charged for individual equity and debt securities
transactions). Fidelity enables TLPW to obtain many no-load mutual funds
without transaction charges and other no-load funds at nominal transaction
charges. Fidelity’s commission rates are generally considered discounted from
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customary retail commission rates. However, the commissions and transaction
fees charged by Fidelity may be higher or lower than those charged by other
custodians and broker-dealers.
As part of the arrangement, Fidelity also makes available to TLPW, at no
additional charge to TLPW, certain research and brokerage services, including
research services obtained by Fidelity directly from independent research
companies.
As a result of receiving such services for no additional cost, TLPW may have an
incentive to continue to use or expand the use of Fidelity's services. TLPW
examined this potential conflict of interest when it chose to enter into a
relationship with Fidelity and has determined that the relationship is in the best
interests of TLPW's clients and satisfies its client obligations, including its duty to
seek best execution. A client may pay a commission that is higher than another
qualified broker-dealer might charge to affect the same transaction where the
TLPW determines in good faith that the commission is reasonable in relation to
the value of the brokerage and research services received. In seeking best
execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the
full range of a broker-dealer’s services, including the value of research provided,
execution capability, commission rates, and responsiveness. Accordingly, although
TLPW will seek competitive rates, to the benefit of all clients, it may not
necessarily obtain the lowest possible commission rates for specific client account
transactions. Although the investment research products and services that may be
obtained by TLPW will generally be used to service all of TLPW’s clients, a
brokerage commission paid by a specific client may be used to pay for research
that is not used in managing that specific client’s account. TLPW periodically (no
less than annually) reviews its brokerage arrangements and execution quality,
taking into consideration factors such as execution capability, transaction costs,
responsiveness, financial strength, and the overall value of services provided by the
custodian. Based on these factors, TLPW has determined that Fidelity Institutional
continues to provide best execution for client transactions.
TLPW and Fidelity are not affiliates, and no broker-dealer affiliated with TLPW is
involved in the relationship between TLPW and Fidelity.
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2. Brokerage for Client Referrals
TLPW receives no referrals from a broker/dealer or third-party in exchange for
using that broker or third-party.
3. Clients Directing Which Broker-Dealer/Custodian to Use
TLPW does not allow clients to direct brokerage orders to a specific custodian or
broker-dealer. TLPW and Fidelity are not affiliates, and no broker-dealer affiliated
with TLPW participates in the relationship between TLPW and Fidelity. Reference
the economic relationship described in Section 12.A.1 to better understand any
potential conflicts of interest or other factors involved in using Fidelity as
custodian for client accounts.
B. Aggregating (Block) Trading for Multiple Client Accounts
TLPW does not utilize block trading. This can impact client accounts in varying
ways depending on market conditions and the time at which that client account is
traded. Declining to block trade can cause more expensive trades for clients. Client
orders will be entered for that client at the time of the account review. TLPW
believes that any impact to client returns should be minimal because the positions
and investments typically used by TLPW are highly liquid investments with
significant average trading volume.
Item 13. Review of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes Those
Reviews
The investment holdings in client accounts are reviewed at least quarterly by the
client’s primary advisor and/or Brad Little. Using a team approach, we review
client accounts for adherence to the client’s respective investment policy/strategy,
risk tolerance levels, objectives, and goals. Client reviews are conducted on a
timing and rotation based on factors such as when the client relationship is
initiated, market volatility and its impact on a client’s asset allocation and other
factors that may lead to a specific client account being reviewed more frequently
than others. TLPW conducts client review meetings at least annually. Our goal is
to ensure that we have a consistent and ongoing understanding of your personal
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financial situation. This process allows us to design and implement wealth
management strategies that are most aligned to your needs and goals.
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts
Reviews may be triggered by significant market, economic or political events, or by
changes in a client's financial situations (such as retirement, change of
employment, physical move, or inheritance). These factors, along with additional
factors described in Item 13A may lead to a specific client account being reviewed
more frequently than others.
C. Content and Frequency of Regular Reports Provided to Clients
A written report that details the client’s accounts (including assets owned and
asset value) will come from the custodian. This report will be provided at least
quarterly. Additionally, TLPW will provide a monthly portfolio summary that
details client asset allocation, top holdings, and performance data.
Item 14. Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice Rendered
to Clients
TLPW receives economic benefits related to advice rendered to TLPW clients as
described in Item 12.1.
B. Compensation to Non-Advisory Personnel for Client Referrals
This does not apply to TLPW.
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Item 15. Custody
TLPW, with client written authority, has limited custody of client’s assets through
direct fee deduction of TLPW’s fees only. If the client chooses to be billed directly
by Fidelity Institutional, a division of FMR, LLC., TLPW would have constructive
custody over that account and must have written authorization from the client to
do so. Clients will receive account statements directly from the qualified custodian
at least quarterly. TLPW urges clients to carefully review these statements and
compare them to any reports provided by TLPW.
TLPW’s reports may vary from custodian statements based on accounting
methodologies, reporting dates, or valuation methods of certain securities. Clients
should rely on custodian statements as the official record of their accounts.
Item 16. Investment Discretion
For those client accounts where TLPW will have investment discretion, the client
has given TLPW written discretionary authority over the client’s accounts with
respect to securities to be bought or sold and the amount of securities to be
bought or sold. Details of this relationship are fully disclosed to the client before
any advisory relationship has commenced. The client provides TLPW discretionary
authority via a discretionary investment management clause in the Investment
Advisory Contract and/or a limited power of attorney clause in the contract
between the client and the custodian. In the case of SMAs, TLPW can select,
terminate or change managers. Any third -party manager agreement (including
additional management fees) will be detailed in the investment advisory
agreement.
Item 17. Voting Client Securities (Proxy Voting)
TLPW will not ask for, nor accept voting authority for client securities. Clients will
receive proxies directly from the issuer of the security or the custodian. Clients
should direct all proxy questions to the issuer of the security.
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Item 18. Financial Information
A. Balance Sheet
TLPW does not require nor solicit prepayment of more than $500 in fees per client,
six months or more in advance and therefore does not need to include a balance
sheet with this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to Meet
Contractual Commitments to Clients
Neither TLPW nor its management have any financial conditions that are likely to
reasonably impair our ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
TLPW has not been the subject of a bankruptcy petition in the last ten years.
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