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TMB Capital Partners, LLC
Form ADV Part 2A – Disclosure Brochure
Effective: February 4, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices
of TMB Capital Partners, LLC (“TMB Capital” or the “Advisor”). If you have any questions about the content of this
Disclosure Brochure, please contact the Advisor at 501-671-1140.
TMB Capital is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure
Brochure provides information about TMB Capital to assist you in determining whether to retain the Advisor.
Additional information about TMB Capital and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 335750.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of TMB Capital. For convenience, the Advisor has combined these documents into a single disclosure
document.
TMB Capital believes that communication and transparency are the foundation of its relationship with clients and will
continually strive to provide you with complete and accurate information at all times. TMB Capital encourages all
current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the
Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since its last filing and distribution to
clients:
• The Advisor has established an institutional relationship with Fidelity. Please see Item 12 and 14 for additional
information.
• The Advisor offers a wrap fee program. Please see Item 4 and Appendix 1 for more information.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes
in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure
or a Summary of Material Changes shall be provided to you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 335750. You may also
request a copy of this Disclosure Brochure at any time by contacting the Advisor at 501-671-1140.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 2
Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................... 1
Item 2 – Material Changes ..................................................................................................................................... 3
Item 3 – Table of Contents .................................................................................................................................... 4
Item 4 – Advisory Services ................................................................................................................................... 4
A. Firm Information ............................................................................................................................................................. 4
B. Advisory Services Offered .............................................................................................................................................. 4
C. Client Account Management .......................................................................................................................................... 6
D. Wrap Fee Programs ....................................................................................................................................................... 6
E. Assets Under Management ............................................................................................................................................ 6
Item 5 – Fees and Compensation ......................................................................................................................... 6
A. Fees for Advisory Services ............................................................................................................................................. 6
B. Fee Billing ....................................................................................................................................................................... 7
C. Other Fees and Expenses ............................................................................................................................................. 7
D. Advance Payment of Fees and Termination .................................................................................................................. 8
E. Compensation for Sales of Securities ............................................................................................................................ 8
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 8
Item 7 – Types of Clients ....................................................................................................................................... 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................................... 9
A. Methods of Analysis ....................................................................................................................................................... 9
B. Risk of Loss .................................................................................................................................................................... 9
Item 9 – Disciplinary Information ....................................................................................................................... 11
Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 11
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 11
A. Code of Ethics .............................................................................................................................................................. 11
B. Personal Trading with Material Interest ........................................................................................................................ 11
C. Personal Trading in Same Securities as Clients .......................................................................................................... 11
D. Personal Trading at Same Time as Client ................................................................................................................... 11
Item 12 – Brokerage Practices ............................................................................................................................ 12
A. Recommendation of Custodian[s] ................................................................................................................................ 12
B. Aggregating and Allocating Trades .............................................................................................................................. 12
Item 13 – Review of Accounts ............................................................................................................................ 13
A. Frequency of Reviews .................................................................................................................................................. 13
B. Causes for Reviews ..................................................................................................................................................... 13
C. Review Reports ............................................................................................................................................................ 13
Item 14 – Client Referrals and Other Compensation ........................................................................................ 13
A. Compensation Received by TMB Capital ..................................................................................................................... 13
B. Compensation for Client Referrals ............................................................................................................................... 14
Item 15 – Custody ................................................................................................................................................ 14
Item 16 – Investment Discretion ......................................................................................................................... 14
Item 17 – Voting Client Securities ...................................................................................................................... 14
Item 18 – Financial Information .......................................................................................................................... 14
Appendix 1 - Wrap Fee Program………………………………………………………………………………………...15
Privacy Policy ...................................................................................................................................................... 34
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 3
Item 4 – Advisory Services
A. Firm Information
TMB Capital Partners, LLC (“TMB Capital” or the “Advisor”) is a registered investment advisor with the U.S. Securities
and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under the laws of the
State of Arkansas. TMB Capital was founded in February 2025. The Advisor is owned by TMB Capital Partners
Holding Company LLC, and operated by Scott E. Tabor (Principal and Chief Compliance Officer), William M.
McMillan, AIF® (Principal), and Benjamin A. Bailey (Principal). This Disclosure Brochure provides information
regarding the qualifications, business practices, and the advisory services provided by TMB Capital.
B. Advisory Services Offered
TMB Capital offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses,
banks, corporations, charities, and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the
Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts
of interest. TMB Capital's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Wealth Management Services
TMB Capital provides customized wealth management services for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management services and a broad
range of comprehensive financial planning.
Investment Management Services – The Advisor provides discretionary investment management services. TMB
Capital works closely with each Client to identify their investment goals and objectives as well as risk tolerance and
financial situation in order to create a portfolio strategy. TMB Capital will then construct an investment portfolio mostly
utilizing model portfolios to meet the Client’s investment goals. These model portfolios are primarily made up of
exchange-traded funds (“ETFs”), mutual funds, and individual stocks. The Advisor may also utilize individual bonds,
options contracts, and/or alternative investments to meet the needs of its Clients. The Advisor may retain other types
of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or
other reasons as identified between the Advisor and the Client.
TMB Capital’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market conditions.
TMB Capital will construct, implement and monitor the portfolio to ensure it meets the goals, objectives,
circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable
restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
TMB Capital evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. TMB Capital may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. TMB Capital may recommend specific positions to increase sector or asset class weightings. The Advisor
may recommend employing cash positions as a possible hedge against market movement.
TMB Capital may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains
or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting
of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any
risk deemed unacceptable for the Client’s risk tolerance.
At no time will TMB Capital accept or maintain custody of a Client’s funds or securities, except for the limited authority
as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 4
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts
or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee
Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws
governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment
advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or
recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another
IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a
recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a
result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by
the Advisor.
Financial Planning Services – The Advisor provides a variety of financial planning and consulting services to Clients
as part of its wealth management services. Services are offered in several areas of a Client’s financial situation,
depending on their goals and objectives. Generally, such financial planning services involve preparing a formal
financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This
planning or consulting may encompass one or more areas of need, including but not limited to, investment planning,
retirement planning, personal savings, education savings, insurance needs and other areas of a Client’s financial
situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations
may be made that the Client start or revise their investment programs, commence or alter retirement savings,
establish education savings and/or charitable giving programs.
TMB Capital may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not
provide a written summary. Plans or consultations are typically completed within six (6) months of contract date,
assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for
investment management services or to increase the level of investment assets with the Advisor, as it would increase
the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made
by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the
recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the
Advisor.
Retirement Plan Advisory Services
The Advisor provides 3(21) and 3(38) retirement plan advisory services on behalf of the retirement plans (each a
“Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist
the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is
customized to the needs of the Plan and Plan Sponsor. Services generally include:
Investment Policy Statement (“IPS”) Design and Monitoring
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
•
• Ongoing Investment Recommendation and Assistance
• Performance Reports
• ERISA 404(c) Assistance
• Benchmarking Services
These services are provided by the Advisor serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor
is provided with a written description of the Advisor’s fiduciary status, the specific services to be rendered and all
direct and indirect compensation the Advisor reasonably expects under the engagement.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 5
Donor Advised Fund Services – The Advisor also provides the Raymond James Charitable Donor Advised Fund
(“DAF”) and the Arkansas Community Foundation Donor Advised Fund (“DAF”) to Clients via Raymond James
Charitable and Arkansas Community Foundation, both are a web-based interface and administrative solution for
charitable giving to philanthropic vehicles via the Raymond James Charitable Fund (“RJCF”) and the Arkansas
Community Foundation (“ACF”), both are IRS approved philanthropic vehicle established for the purpose of managing
charitable donations contributed by or on behalf of donor clients. The DAF allows the Advisor to actively manage
assets that have been donated to and are owned by RJCF or ACF, while charging an investment management fee.
The Advisor’s DAF participation is in conjunction with approval by the RJCF or ACF Investment Committee for the
Advisor to operate as an advisory manager on the platform. Both the Raymond James Charitable Fund and Arkansas
Community Foundation Charitable Fund are independent companies and unaffiliated with the Advisor.
C. Client Account Management
Prior to engaging TMB Capital to provide investment advisory services, each Client is required to enter into an
agreement with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
• Establishing an Investment Strategy – TMB Capital, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
• Asset Allocation – TMB Capital will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – TMB Capital will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
•
Investment Management and Supervision – TMB Capital will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
TMB Capital includes, securities transaction fees (herein “Covered Costs”) together with its wealth management
fees for Client accounts held at Fidelity. Including these fees into a single asset-based fee is considered a “Wrap
Fee Program”. The Advisor customizes its wealth management services for its Clients. The Advisor sponsors the
TMB Capital Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending
on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in
total fees than if the Client paid its own transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure,
which is included as a supplement to this Disclosure Brochure.
E. Assets Under Management
As of December 31, 2025, TMB Capital manages $867,846,603 in client assets, all of which are managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
agreement with the Advisor.
A. Fees for Advisory Services
Wealth Management Services
Wealth management fees are paid in advance of each calendar quarter, pursuant to the terms of the wealth
management agreement. Wealth management fees are based on the market value of assets under management at
the end of the prior calendar quarter. Wealth management fees are based on the following blended tiered schedule:
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 6
Assets Under Management ($)
Annual Rate (%)
First $1,000,000
Next $1,000,000
Next $1,500,000
Next $1,500,000
Next $5,000,000
Above $10,000,000
1.00%
0.85%
0.75%
0.50%
0.40%
Negotiable
Certain legacy client relationships may be charged a higher wealth management fee than described in the blended
tiered schedule above. The wealth management fee in the first quarter of service is prorated from the inception date of
the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s
fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts
managed by TMB Capital will be independently valued by the Custodian. The Advisor will conduct periodic reviews of
the Custodian’s valuation to ensure accurate billing.
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other
related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor
shall not receive any portion of these commissions, fees, and costs.
Retirement Plan Advisory Services
Retirement plan advisory fees are charged an annual asset-based fee of up to 1.00%. Fees may be billed monthly
or quarterly (“Billing Period”) in advance or arrears pursuant to the terms of the retirement plan advisory agreement.
Retirement plan fees are based on the market value of assets under management at the end of the Billing Period.
Fees may be negotiable depending on the size and complexity of the Plan but shall not exceed the fee range stated
above.
B. Fee Billing
Wealth Management Services
Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at
the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted
from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the
quarterly rate (annual rate divided by 4) to the total assets under management with TMB Capital at the end of the
prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of
the wealth management fee. Clients are urged to also review and compare the statement provided by the Advisor to
the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide
written authorization permitting wealth management fees to be deducted by TMB Capital to be paid directly from their
account[s] held by the Custodian as part of the wealth management agreement and separate account forms provided
by the Custodian.
Retirement Plan Advisory Services
Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan,
depending on the terms of the retirement plan advisory agreement.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf
of the Client’s accounts. TMB Capital includes Covered Costs as part of its overall wealth management fee for
account[s] held at Fidelity through the TMB Capital Wrap Fee Program. Securities transaction fees for Client-
directed trades may be charged back to the Client. Please see Item 4.D. above as well as Appendix 1 – Wrap Fee
Program Brochure.
Clients may incur certain fees or charges imposed by third parties, other than TMB Capital, in connection with
investments made on behalf of the Client’s account[s]. For accounts at Raymond James the Client is responsible for
all custody and securities execution fees charged by Raymond James, as applicable. The Advisor's recommended
Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 7
the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian
typically charges for mutual funds and other types of investments. For accounts at Raymond James, the fees charged
by TMB Capital are separate and distinct from these custody and execution fees.
In addition, all fees paid to TMB Capital wealth management services are separate and distinct from the expenses
charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in
each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds,
other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible
distribution fee. A Client may be able to invest in these products directly, without the services of TMB Capital, but
would not receive the services provided by TMB Capital which are designed, among other things, to assist the Client
in determining which products or services are most appropriate for each Client’s financial situation and objectives.
Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by TMB Capital to
fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information.
D. Advance Payment of Fees and Termination
Wealth Management Services
TMB Capital may be compensated for its wealth management services in advance of the quarter in which services
are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance
written notice to the other party. The Client may also terminate the wealth management agreement within five (5)
business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will
incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and
payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid wealth management fees from
the effective date of termination to the end of the quarter. The Client’s wealth management agreement with the
Advisor is non-transferable without the Client’s prior consent.
Retirement Plan Advisory Services
The Advisor may be compensated for its services at the beginning of the Billing Period before services are rendered
pursuant to the terms of the retirement plan advisory agreement. Either party may request to terminate a retirement
plan advisory agreement, at any time, by providing advance written notice to the other party. The Client shall be
responsible for fees up to and including the effective date of termination. If the fees are billed in advance, the Advisor
will refund any unearned, prepaid retirement plan advisory fees from the effective date of termination to the end of
the Billing Period. The Client’s retirement plan services agreement with the Advisor is non-transferable without the
Client’s prior consent.
E. Compensation for Sales of Securities
TMB Capital does not buy or sell securities to earn commissions and does not receive any compensation for securities
transactions in any Client account, other than the investment advisory fees noted above.
Insurance Agency Affiliation
Certain Advisory Persons are licensed as independent insurance professionals. As an independent insurance
professional, an Advisory Person may earn commission-based compensation for selling insurance products,
including insurance products offered to Clients. Insurance commissions earned by the Advisory Person are separate
and in addition to wealth management fees. This practice presents a conflict of interest as an Advisory Person who
is also an insurance professional will have an incentive to recommend insurance products to the Client for the purpose
of generating commissions rather than solely based on the Client’s needs. Clients are under no obligation, contractual
or otherwise, to purchase insurance products through any Advisory Person affiliated with the Advisor. Please see
Item 10 below.
Item 6 – Performance-Based Fees and Side-By-Side Management
TMB Capital does not charge performance-based fees for its investment advisory services. The fees charged by TMB
Capital are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities
held by any Client.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 8
TMB Capital does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund
or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients.
Item 7 – Types of Clients
TMB Capital offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses,
banks, corporations, charities, and retirement plans. TMB Capital generally does not impose a minimum relationship
size.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
TMB Capital employs a fundamental analysis method in developing investment strategies for its Clients. Research
and analysis from TMB Capital are derived from numerous sources, including financial media companies, third-party
research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press
releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists
generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed.
Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value
discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does
not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the
fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these
economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s
review process are included below in Item 13 – Review of Accounts.
As noted above, TMB Capital generally employs a long-term investment strategy for its Clients, as consistent with
their financial goals. TMB Capital will typically hold all or a portion of a security for more than a year, but may hold for
shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, TMB Capital
may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the
fundamentals of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should
be prepared to bear the potential risk of loss. TMB Capital will assist Clients in determining an appropriate strategy
based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet
their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may
lose value and may have negative investment performance. The Advisor monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are
included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 9
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will
fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based
on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread
and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from
the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point
in the day may have a different price than the same ETF purchased or sold a short time later.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall
if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate
of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was
previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds
the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated
with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment
obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating
which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk
that a bond may not be sold as quickly as there is no readily available market for the bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price
as a mutual fund purchased later that same day.
Options Contracts
Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are
leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This
leverage can compound gains or losses.
Alternative Investments (Limited Partnerships)
The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An
investor could lose all or a portion of their investment. Such investments often have concentrated positions and
investments that may carry higher risks. Client should only have a portion of their assets in these investments.
Real Estate Investment Trusts (“REITs”)
Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks
associated with investing in the real estate industry in general. For example, equity REITs may be affected by
changes in the value of the underlying property owned by the REITs, while mortgage REITs may be affected by the
quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers, and self-
liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest rates rise, the
value of the REIT may decline).
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 10
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving TMB Capital or its management persons. TMB
Capital values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due
diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory
Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching
with the Advisor’s firm name or CRD# 335750.
Item 10 – Other Financial Industry Activities and Affiliations
Insurance Agency Affiliation
As noted in Item 5, certain Advisory Persons are licensed insurance professionals. Implementations of insurance
recommendations are separate and apart from one’s role with the Advisor. As an insurance professional, the Advisory
Person will receive customary commissions and other related revenues from the various insurance companies whose
products are sold. Advisory Persons are not required to offer the products of any particular insurance company.
Commissions generated by insurance sales do not offset wealth management fees. This presents a conflict of interest
in recommending certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by the Advisor or Advisory Persons.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
TMB Capital has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each
Client. This Code applies to all persons associated with TMB Capital (“Supervised Persons”). The Code was
developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client.
TMB Capital and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the
obligation of TMB Capital’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to
the general principles that guide the Code. The Code covers a range of topics that address employee ethics and
conflicts of interest. To request a copy of the Code, please contact the Advisor at 501-671-1140.
B. Personal Trading with Material Interest
TMB Capital allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. TMB Capital does not act as principal in any transactions. In addition, the Advisor
does not act as the general partner of a fund, or advise an investment company. TMB Capital does not have a material
interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
TMB Capital allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and
procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public
information controls); gifts and entertainment; outside business activities and personal securities reporting. When
trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The
fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated
by TMB Capital requiring reporting of personal securities trades by its Supervised Persons for review by the Chief
Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the
misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While TMB Capital allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At
no time will TMB Capital, or any Supervised Person of TMB Capital, transact in any security to the detriment
of any Client.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 11
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
TMB Capital does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and
authorize TMB Capital to direct trades to the Custodian as agreed upon in the wealth management agreement.
Further, TMB Capital does not have the discretionary authority to negotiate commissions on behalf of Clients on a
trade-by-trade basis.
Where TMB Capital does not exercise discretion over the selection of the Custodian, it may recommend the
Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended
by the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by TMB
Capital. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not
engaged. TMB Capital may recommend the Custodian based on criteria such as, but not limited to, reasonableness
of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of
the Custodian’s offices.
The Advisor will generally recommend that Clients establish their account[s] at Raymond James & Associates, Inc.,
member New York Stock Exchange/SPIC (“Raymond James”) or Fidelity Clearing and Custody Solutions and related
divisions and entities of Fidelity Investments, Inc., including National Financial Services LLC, and Fidelity Brokerage
Services LLC, (collectively “Fidelity”). Raymond James and Fidelity are FINRA-registered broker-dealers and New
York Stock Exchange/SIPC members. Raymond James or Fidelity will serve as the Client’s “qualified custodian”. The
Advisor maintains institutional relationships with Raymond James and Fidelity, whereby the Advisor receives
economic benefits from the Custodian. Please see Item 14 below.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters
into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other
services. TMB Capital does not participate in soft dollar programs sponsored or offered by any broker-
dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see
Item 14 below.
2. Brokerage Referrals - TMB Capital does not receive any compensation from any third party in connection with
the recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where TMB Capital will place trades
within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded
within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security
from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security
into one Client account from another Client’s account[s]). TMB Capital will not be obligated to select competitive bids
on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs
are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution,
4) confidentiality and 5) skill required of the Custodian. TMB Capital will execute its transactions through the
Custodian as authorized by the Client. TMB Capital may aggregate orders in a block trade or trades when securities
are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block
trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of
each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written
statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’
accounts.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 12
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Scott E. Tabor, Chief Compliance
Officer of TMB Capital. Formal reviews are generally conducted at least annually or more frequently depending on
the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually.
Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major
changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or
withdrawals in the Client’s account[s]. The Client is encouraged to notify TMB Capital if changes occur in the Client’s
personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be
triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements
are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s
website so that the Client may view these reports and their account activity. Client brokerage statements will include
all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with
periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by TMB Capital
TMB Capital is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product.
TMB Capital does not receive commissions or other compensation from product sponsors, broker-dealers or any un-
related third party. TMB Capital may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys,
accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise,
TMB Capital may receive non-compensated referrals of new Clients from various third-parties.
Participation in Institutional Advisor Platform – Raymond James
As noted in item 12, the Advisor has established an institutional relationship with Raymond James to assist the
Advisor in managing Client account[s]. As part of the arrangement, Raymond James makes available to the Advisor,
certain research and brokerage services, including research services obtained by Raymond James directly from
independent research companies. The Advisor may also receive additional services and support from Raymond
James. The Advisor has an incentive to continue to use or expand the use of Raymond James's services. The Advisor
examined this potential conflict of interest when it chose to enter into the relationship with Raymond James and has
determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations,
including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and
related support because the Advisor renders wealth management services to Clients that maintain assets at
Raymond James. The software and related systems support may benefit the Advisor, but not its Clients directly. In
fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should
be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these
benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar
software, systems support, or services.
Participation in Institutional Advisor Platform – Fidelity
Alos, as noted in item 12, the Advisor has established an institutional relationship with Fidelity to assist the Advisor in
managing Client account[s].
As part of the arrangement, Fidelity also makes available to the Advisor, at no additional charge to the Advisor, certain
research and brokerage services, including research services obtained by Fidelity directly from independent research
companies. The Advisor may also receive additional services and support from Fidelity. As a result of receiving such
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 13
services for no additional cost, the Advisor may have an incentive to continue to use or expand the use of Fidelity's
services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with
Fidelity and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client
obligations, including its duty to seek best execution. Please see Item 12 above.
The Advisor receives access to software and related support without cost because the Advisor renders investment
management services to Clients that maintain assets at Fidelity. The software and related systems support may
benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times
to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from
a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this
Custodian over one that does not furnish similar software, systems support, or services. In addition, Fidelity has
provided the Advisor with financial support in the launch of the Advisor and reimbursements for various third-party
service providers.
B. Compensation for Client Referrals
The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client
referrals.
Item 15 – Custody
TMB Capital is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all
assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities
and direct TMB Capital to utilize that Custodian for security transactions in the account[s]. The Client should review
statements provided by the Custodian, as the Custodian does not perform this review. For more information about
custodians and brokerage practices, see Item 12 – Brokerage Practices.
Item 16 – Investment Discretion
TMB Capital generally has discretion over the selection and amount of securities to be bought or sold in Client
accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be
subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to
by TMB Capital. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such
authority will be evidenced by the Client's execution of a wealth management agreement containing all applicable
limitations to such authority. All discretionary trades made by TMB Capital will be in accordance with each Client's
investment objectives and goals.
Item 17 – Voting Client Securities
TMB Capital does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly
from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the
sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither TMB Capital, nor its management, have any adverse financial situations that would reasonably impair the
ability of TMB Capital to meet all obligations to its Clients. Neither TMB Capital, nor any of its Advisory Persons, have
been subject to a bankruptcy or financial compromise. TMB Capital is not required to deliver a balance sheet along
with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be
performed six months or more in the future.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 14
TMB Capital Partners, LLC
Form ADV Part 2A – Appendix 1
(“Wrap Fee Program Brochure”)
Effective: February 4, 2026
This Form ADV2A - Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications and
business practices for TMB Capital Partners, LLC (“TMB Capital” or the “Advisor”) services when offering services
pursuant to a wrap program. This Wrap Fee Program Brochure shall always be accompanied by the TMB Capital
Disclosure Brochure, which provides complete details on the business practices of the Advisor. If you did not
receive the complete TMB Capital Disclosure Brochure or you have any questions about the contents of this Wrap
Fee Program Brochure or the TMB Capital Disclosure Brochure, please contact the Advisor at 501-671-1140.
TMB Capital is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”) The
information in this Wrap Fee Program Brochure has not been approved or verified by the SEC or by any state
securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This
Wrap Fee Program Brochure provides information about TMB Capital to assist you in determining whether to retain
the Advisor.
Additional information about TMB Capital and its advisory persons are available on the SEC’s website at
www.adviserinfo.sec.gov by searching the Advisor’s firm name or CRD# 335750.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 15
Item 2 – Material Changes
Form ADV 2A - Appendix 1 provides information about a variety of topics relating to an Advisor’s business practices
and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses the Wrap Fee Program offered by
the Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since its last filing and distribution to
clients:
• The Advisor has established an institutional relationship with Fidelity. Please see Item 12 and 14 for additional
information.
• The Advisor offers a wrap fee program. Please see Item 4 and Appendix 1 for more information.
Future Changes
From time to time, the Advisor may amend this Wrap Fee Program Brochure to reflect changes in business
practices, changes in regulations or routine annual updates as required by the securities regulators. This complete
Wrap Fee Program Brochure (along with the complete TMB Capital Disclosure Brochure) or a Summary of Material
Changes shall be provided to you annually and if a material change occurs in the business practices of TMB
Capital.
At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at the
SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching for the Advisor’s firm
name or CRD# 335750. You may also request a copy of this Disclosure Brochure at any time, by contacting the
Advisor at 501-671-1140.
Item 3 – Table of Contents
Item 2 – Material Changes ..................................................................................................................................... 2
Item 3 – Table of Contents .................................................................................................................................... 3
Item 4 – Services Fees and Compensation ....................................................................................................... 17
Item 5 – Account Requirements and Types of Clients ....................................................................................... 4
Item 6 – Portfolio Manager Selection and Evaluation ........................................................................................ 4
Item 7 – Client Information Provided to Portfolio Managers ............................................................................. 4
Item 8 – Client Contact with Portfolio Managers ................................................................................................ 6
Item 9 – Additional Information ............................................................................................................................ 6
Item 10 – Requirements for State-Registered Advisors ..................................................................................... 6
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 16
Item 4 – Services Fees and Compensation
A. Services
TMB Capital provides customized investment advisory services for its Clients. This Wrap Fee Program Brochure is
provided as a supplement to the TMB Capital Disclosure Brochure (Form ADV 2A). This Wrap Fee Program
Brochure is provided along with the complete Disclosure Brochure to provide full details of the business practices
and fees when selecting TMB Capital as your investment advisor.
As part of the investment advisory fees noted in Item 5 of the Disclosure Brochure, TMB Capital includes, in
addition to securities transaction fees (herein “Covered Costs”) as part of the overall wealth management fee for
accounts held at Fidelity. Securities regulations often refer to this combined fee structure as a “Wrap Fee Program”.
The Advisor’s recommended Custodians do not charge securities transaction fees for exchange-traded fund
(“ETF”) and equity trades in Client accounts, but typically charges for mutual funds and other types of investments.
The Advisor sponsors the TMB Capital Wrap Fee Program.
The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination of
Covered Costs into a single “bundled” wealth management fee. This Wrap Fee Program Brochure references back
to the TMB Capital Disclosure Brochure in which this Wrap Fee Program Brochure serves as an Appendix. Please
see Item 4 – Advisory Services of the Disclosure Brochure for details on TMB Capital’s investment
philosophy and related services.
B. Program Costs
Advisory services provided by TMB Capital are offered in a wrap fee structure whereby Covered Costs are included
in the overall wealth management fee paid to TMB Capital for accounts held at Fidelity. As the level of activity in a
Client’s account[s] may vary from year to year, the annual cost to the Client may be more or less than engaging for
advisory services where the Covered Costs are borne separately by the Client. The cost of the Wrap Fee Program
varies depending on services to be provided to each Client, however, the Client is not charged more if there is
higher trading activity or other Covered Costs. A Wrap Fee structure presents a conflict of interest as the Advisor is
incentivized to limit the number of trades placed in the Client’s account[s] or to utilize securities that do not have
transaction fees. As noted above, the Advisor’s recommended Custodians do not charge securities transaction fees
for ETF and equity trades in Client accounts, but typically charges for mutual funds and other types of investments.
As such, the Advisor is incentivized to utilize ETFs and other equity securities to limit the overall cost to the Advisor.
The Advisor will only place Client assets into a Wrap Fee Program when it is believed to be in the Client’s best
interest. Please see Item 5 – Fees and Compensation of the Disclosure Brochure for complete details on
fees.
C. Fees
Wealth Management Services
Wealth management fees are paid in advance of each calendar quarter, pursuant to the terms of the wealth
management agreement. Wealth management fees are based on the market value of assets under management at
the end of the prior calendar quarter. Wealth management fees are based on the following blended tiered schedule:
Assets Under Management ($)
Annual Rate (%)
First $1,000,000
Next $1,000,000
Next $1,500,000
Next $1,500,000
Next $5,000,000
Above $10,000,000
1.00%
0.85%
0.75%
0.50%
0.40%
Negotiable
Certain legacy client relationships may be charged a higher wealth management fee than described in the blended
tiered schedule above. The wealth management fee in the first quarter of service is prorated from the inception date of
the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 17
fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts
managed by TMB Capital will be independently valued by the Custodian. The Advisor will conduct periodic reviews of
the Custodian’s valuation to ensure accurate billing.
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other
related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor
shall not receive any portion of these commissions, fees, and costs.
Retirement Plan Advisory Services
Retirement plan advisory fees are charged an annual asset-based fee of up to 1.00%. Fees may be billed monthly
or quarterly (“Billing Period”) in advance or arrears pursuant to the terms of the retirement plan advisory agreement.
Retirement plan fees are based on the market value of assets under management at the end of the Billing Period.
Fees may be negotiable depending on the size and complexity of the Plan but shall not exceed the fee range stated
above.
As noted above, the Wrap Fee Program includes Covered Costs incurred in connection with the discretionary
investment management services provided by TMB Capital, as part of its overall investment advisory fee.
In addition, all fees paid to TMB Capital for investment advisory services or part of the Wrap Fee Program are
separate and distinct from the expenses charged by mutual funds and exchange-traded funds to their shareholders,
if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will
generally be used to pay management fees for the funds, other fund expenses, account administration (e.g.,
custody, brokerage and account reporting), and a possible distribution fee. Securities transaction fees for Client-
directed trades will be charged back to the Client. In connection with the discretionary investment management
services provided by TMB Capital, the Client will incur other costs assessed by the Custodian or other third parties,
other than the Covered Costs noted above, such securities transaction fees. The Advisor does not control nor
share in these fees. The Client should review both the fees charged by the fund[s] and the fees charged by TMB
Capital to fully understand the total fees to be paid. Please see Item 5.C. – Other Fees and Expenses in the
Disclosure Brochure (included with this Wrap Fee Program Brochure).
D. Compensation
TMB Capital is the sponsor and portfolio manager of this Wrap Fee Program. TMB Capital receives wealth
management fees paid by Clients for participating in the Wrap Fee Program and pays the Covered Costs
associated with the management of the Client’s account[s].
Item 5 – Account Requirements and Types of Clients
TMB Capital offers wealth management services to individuals, high net worth individuals, trusts, estates,
businesses, banks, corporations, charities, and retirement plans. TMB Capital generally does not impose a
minimum account size for establishing a relationship. Please see Item 7 – Types of Clients in the Disclosure
Brochure for additional information.
Item 6 – Portfolio Manager Selection and Evaluation
Portfolio Manager Selection
TMB Capital serves as sponsor and as portfolio manager for the services under this Wrap Fee Program.
Related Persons
TMB Capital personnel serve as portfolio managers for this Wrap Fee Program.
Performance-Based Fees
TMB Capital does not charge performance-based fees for its investment advisory services. The fees charged by TMB
Capital are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities
held by any Client.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 18
Supervised Persons
TMB Capital Advisory Persons serve as portfolio managers for all accounts, including the services described in this
Wrap Fee Program Brochure. Details of the advisory services provided are included in Item 4.A. of the Disclosure
Brochure.
Methods of Analysis
Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on the
research and analysis methods employed by the Advisor.
Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should
be prepared to bear the potential risk of loss. TMB Capital will assist Clients in determining an appropriate strategy
based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet
their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may
lose value and may have negative investment performance. The Advisor monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are
included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process.
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will
fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based
on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread
and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from
the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point
in the day may have a different price than the same ETF purchased or sold a short time later.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall
if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate
of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was
previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds
the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated
with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment
obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating
which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk
that a bond may not be sold as quickly as there is no readily available market for the bond.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 19
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price
as a mutual fund purchased later that same day.
Options Contracts
Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are
leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This
leverage can compound gains or losses.
Alternative Investments (Limited Partnerships)
The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An
investor could lose all or a portion of their investment. Such investments often have concentrated positions and
investments that may carry higher risks. Client should only have a portion of their assets in these investments.
Real Estate Investment Trusts (“REITs”)
Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks
associated with investing in the real estate industry in general. For example, equity REITs may be affected by
changes in the value of the underlying property owned by the REITs, while mortgage REITs may be affected by the
quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers, and self-
liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest rates rise, the
value of the REIT may decline).
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor. Please see Item 8.B. – Risk of Loss in the Disclosure Brochure for details on
investment risks.
Proxy Voting
TMB Capital does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly
from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains
the sole responsibility for proxy decisions and voting.
Item 7 – Client Information Provided to Portfolio Managers
TMB Capital is the sponsor and sole portfolio manager for the Program. The Advisor does not share Client
information with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program.
Please also see the TMB Capital Privacy Policy (included after this Wrap Fee Program Brochure).
Item 8 – Client Contact with Portfolio Managers
TMB Capital is a full-service investment management advisory firm. Clients always have direct access to the
Portfolio Managers at TMB Capital.
Item 9 – Additional Information
A. Disciplinary Information and Other Financial Industry Activities and Affiliations
There are no legal, regulatory or disciplinary events involving TMB Capital or its management persons. TMB
Capital values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due
diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory
Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching
with the Advisor’s firm name or CRD# 335750.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 20
Please see Item 9 of the TMB Capital Disclosure Brochure as well as Item 3 of each Advisory Person’s Brochure
Supplement (included with this Wrap Fee Program Brochure) for additional information on how to research the
background of the Advisor and its Advisory Persons.
Other Financial Activities and Affiliations
Please see Item 10 – Other Financial Activities and Affiliation and Item 14 – Client Referrals and Other
Compensation of the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program Brochure).
B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information
TMB Capital has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each Client. This
Code of Ethics applies to all persons subject to TMB Capital’s compliance program (our “Supervised Persons”).
Complete details on the TMB Capital Code of Ethics can be found under Item 11 – Code of Ethics, Participation in
Client Transactions and Personal Trading in the Disclosure Brochure (included with this Wrap Fee Program
Brochure).
Investments in
Review of Accounts
Client accounts are monitored on a regular and continuous basis by Advisory Persons of TMB Capital under the
supervision of the Chief Compliance Officer (“CCO”). Details of the review policies and practices are provided in
Item 13 of the Form ADV Part 2A – Disclosure Brochure.
Other Compensation
Participation in Institutional Advisor Platform – Raymond James
As noted in item 12, the Advisor has established an institutional relationship with Raymond James to assist the
Advisor in managing Client account[s]. As part of the arrangement, Raymond James makes available to the Advisor,
certain research and brokerage services, including research services obtained by Raymond James directly from
independent research companies. The Advisor may also receive additional services and support from Raymond
James. The Advisor has an incentive to continue to use or expand the use of Raymond James's services. The Advisor
examined this potential conflict of interest when it chose to enter into the relationship with Raymond James and has
determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations,
including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and
related support because the Advisor renders wealth management services to Clients that maintain assets at
Raymond James. The software and related systems support may benefit the Advisor, but not its Clients directly. In
fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should
be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these
benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar
software, systems support, or services.
Participation in Institutional Advisor Platform – Fidelity
Alos, as noted in item 12, the Advisor has established an institutional relationship with Fidelity to assist the Advisor in
managing Client account[s].
As part of the arrangement, Fidelity also makes available to the Advisor, at no additional charge to the Advisor, certain
research and brokerage services, including research services obtained by Fidelity directly from independent research
companies. The Advisor may also receive additional services and support from Fidelity. As a result of receiving such
services for no additional cost, the Advisor may have an incentive to continue to use or expand the use of Fidelity's
services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with
Fidelity and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client
obligations, including its duty to seek best execution. Please see Item 12 above.
The Advisor receives access to software and related support without cost because the Advisor renders investment
management services to Clients that maintain assets at Fidelity. The software and related systems support may
benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times
to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from
a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this
Custodian over one that does not furnish similar software, systems support, or services. In addition, Fidelity has
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 21
provided the Advisor with financial support in the launch of the Advisor and reimbursements for various third-party
service providers.
Please se
Item 14 – Other Compensation in the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee
Program Brochure) for details on additional compensation that may be received by TMB Capital or its Advisory
Persons. Each Advisory Person’s Brochure Supplement (also included with this Wrap Fee Program Brochure)
provides details on any outside business activities and the associated compensation.
Client Referrals from Solicitors
The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client
referrals.
Financial Information
Neither TMB Capital, nor its management, have any adverse financial situations that would reasonably impair the
ability of TMB Capital to meet all obligations to its Clients. Neither TMB Capital, nor any of its Advisory Persons, have
been subject to a bankruptcy or financial compromise. TMB Capital is not required to deliver a balance sheet along
with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be
performed six months or more in the future.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 22
Form ADV Part 2B – Brochure Supplement
for
Scott E. Tabor
Principal and Chief Compliance Officer
Effective: February 4, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Scott
E. Tabor (CRD# 2233071) in addition to the information contained in the TMB Capital Partners, LLC (“TMB Capital”
or the “Advisor”, CRD# 335750) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or
if you have any questions about the contents of the TMB Capital Disclosure Brochure or this Brochure Supplement,
please contact us at 501-671-1140.
Additional information about Mr. Tabor is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2233071.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 23
Item 2 – Educational Background and Business Experience
Scott E. Tabor, born in 1968, is dedicated to advising Clients of TMB Capital as a Principal and the Chief Compliance
Officer. Mr. Tabor earned his BSBA in Finance/Insurance from the University of Arkansas, Fayetteville in 1991.
Additional information regarding Mr. Tabor’s employment history is included below.
Employment History:
Principal and Chief Compliance Officer, TMB Capital Partners, LLC
Financial Advisor, Raymond James & Associates, Inc.
07/2025 to Present
02/2013 to 07/2025
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Tabor. Mr. Tabor has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Tabor.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud;
false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or
extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or
disciplinary events to disclose regarding Mr. Tabor.
However, we do encourage you to independently view the background of Mr. Tabor on the Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2233071.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Tabor is also a licensed insurance professional. Implementations of insurance recommendations are separate
and apart from Mr. Tabor’s role with TMB Capital. As an insurance professional, Mr. Tabor will receive customary
commissions and other related revenues from the various insurance companies whose products are sold. Mr. Tabor
is not required to offer the products of any particular insurance company. Commissions generated by insurance sales
do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of
the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Tabor or
the Advisor. Mr. Tabor spends approximately 10% of his time per month in this capacity.
Central Acquisitions
Mr. Tabor also serves as a Co-owner of Central Acquisitions, a termite and pest control business. Mr. Tabor is
compensated for this activity and spends less than 5% of his time per month in this capacity.
Cottondale Lane River LLC
Mr. Tabor also serves as a Partner of Cottondale Lane River LLC, an LLC for a building lease. Mr. Tabor is not
compensated for this activity and spends less than 5% of his time per month in this capacity.
CR Resource Group
Mr. Tabor also serves as a Co-owner of CR Resource Group, a natural resource recycling company. Mr. Tabor is not
compensated for this activity and spends less than 5% of his time per month in this capacity.
AR Game and Fish Foundation
Mr. Tabor is also a Board Member for the AR Game and Fish Foundation, a state natural resource entity. Mr. Tabor
is not compensated for this activity, and spends less than 5% of his time per month in this capacity.
SDT Rev Trust
Mr. Tabor also serves as a Trustee for the SDT Rev Trust, a family trust. Mr. Tabor is compensated for this activity,
and spends approximately 5% of his time per month in this capacity.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 24
Item 5 – Additional Compensation
Mr. Tabor has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Tabor serves as a Principal and the Chief Compliance Officer of TMB Capital. Mr. Tabor can be reached at 501-
671-1140.
TMB Capital has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of TMB Capital. Further, TMB Capital is subject to regulatory
oversight by various agencies. These agencies require registration by TMB Capital and its Supervised Persons. As
a registered entity, TMB Capital is subject to examinations by regulators, which may be announced or unannounced.
TMB Capital is required to periodically update the information provided to these agencies and to provide various
reports regarding the business activities and assets of the Advisor.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 25
Form ADV Part 2B – Brochure Supplement
for
William M. McMillan, AIF®
Principal
Effective: February 4, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of William
M. McMillan, AIF® (CRD# 4268503) in addition to the information contained in the TMB Capital Partners, LLC (“TMB
Capital” or the “Advisor”, CRD# 335750) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the TMB Capital Disclosure Brochure or this Brochure
Supplement, please contact us at 501-671-1140.
Additional information about Mr. McMillan is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4268503.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 26
Item 2 – Educational Background and Business Experience
William M. McMillan, AIF®, born in 1975, is dedicated to advising Clients of TMB Capital as a Principal. Mr. McMillan
earned his Master of Business Administration from University of Memphis in 2000. Mr. McMillan also earned his
Bachelor of Business Administration in Finance from University of Arkansas in 1998. Additional information regarding
Mr. McMillan’s employment history is included below.
Employment History:
Principal, TMB Capital Partners, LLC
Registered Associate, Raymond James & Associates, Inc.
07/2025 to Present
02/2013 to 07/2025
Accredited Investment Fiduciary™ (“AIF®”)
The AIF® mark is held by the Center for Fiduciary Studies, LLC, a Fiduciary360 (fi360) company.
The professional designations awarded by fi360 demonstrate the focus on all the components of a comprehensive
investment process, related fiduciary standards of care, and commitment to excellence. AIF® designees undergo an
initial training program, annual continuing education, and pledge to abide by the designation's code of ethics.
investment
Since October 2002, the Accredited Investment Fiduciary™ (AIF®) designation has been the mark of commitment to
a standard of fiduciary investment excellence. Those who earn the AIF® mark successfully complete a specialized
program on
fiduciary standards of care and subsequently passed a comprehensive
examination. AIF® designees demonstrate a thorough understanding of fi360's Prudent Practices for investment
advisors and stewards.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. McMillan. Mr. McMillan has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. McMillan.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud;
false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or
extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or
disciplinary events to disclose regarding Mr. McMillan.
However, we do encourage you to independently view the background of Mr. McMillan on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
4268503.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. McMillan is also a licensed insurance professional. Implementations of insurance recommendations are separate
and apart from Mr. McMillan’s role with TMB Capital. As an insurance professional, Mr. McMillan will receive
customary commissions and other related revenues from the various insurance companies whose products are sold.
Mr. McMillan is not required to offer the products of any particular insurance company. Commissions generated by
insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any recommendations
made by Mr. McMillan or the Advisor. Mr. McMillan spends approximately 10% of his time per month in this capacity.
Item 5 – Additional Compensation
Mr. McMillan has an additional business activity where compensation is received that is detailed in Item 4 above.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 27
Item 6 – Supervision
Mr. McMillan serves as a Principal of TMB Capital and is supervised by Scott Tabor, the Chief Compliance Officer.
Mr. Tabor can be reached at 501-671-1140.
TMB Capital has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of TMB Capital. Further, TMB Capital is subject to regulatory
oversight by various agencies. These agencies require registration by TMB Capital and its Supervised Persons. As
a registered entity, TMB Capital is subject to examinations by regulators, which may be announced or unannounced.
TMB Capital is required to periodically update the information provided to these agencies and to provide various
reports regarding the business activities and assets of the Advisor.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 28
Form ADV Part 2B – Brochure Supplement
for
Benjamin A. Bailey
Principal
Effective: February 4, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Benjamin A. Bailey (CRD# 5171116) in addition to the information contained in the TMB Capital Partners, LLC (“TMB
Capital” or the “Advisor”, CRD# 335750) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the TMB Capital Disclosure Brochure or this Brochure
Supplement, please contact us at 501-671-1140.
Additional information about Mr. Bailey is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5171116.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 29
Item 2 – Educational Background and Business Experience
Benjamin A. Bailey, born in 1984, is dedicated to advising Clients of TMB Capital as a Principal. Mr. Bailey earned a
BSBA in Finance with an emphasis on Financial Management of Investments from University of Arkansas in 2006.
Additional information regarding Mr. Bailey’s employment history is included below.
Employment History:
Principal, TMB Capital Partners, LLC
First Vice President, Financial Advisor, Raymond James & Associates, Inc.
07/2025 to Present
02/2013 to 07/2025
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Bailey. Mr. Bailey has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Bailey.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud;
false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or
extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or
disciplinary events to disclose regarding Mr. Bailey.
However, we do encourage you to independently view the background of Mr. Bailey on the Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5171116.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Bailey is also a licensed insurance professional. Implementations of insurance recommendations are separate
and apart from Mr. Bailey’s role with TMB Capital. As an insurance professional, Mr. Bailey will receive customary
commissions and other related revenues from the various insurance companies whose products are sold. Mr. Bailey
is not required to offer the products of any particular insurance company. Commissions generated by insurance sales
do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of
the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Bailey or
the Advisor. Mr. Bailey spends approximately 10% of his time per month in this capacity.
Item 5 – Additional Compensation
Mr. Bailey has an additional business activity where compensation is received that is detailed in Item 4 above.
Item 6 – Supervision
Mr. Bailey serves as a Principal of TMB Capital and is supervised by Scott Tabor, the Chief Compliance Officer. Mr.
Tabor can be reached at 501-671-1140.
TMB Capital has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of TMB Capital. Further, TMB Capital is subject to regulatory
oversight by various agencies. These agencies require registration by TMB Capital and its Supervised Persons. As
a registered entity, TMB Capital is subject to examinations by regulators, which may be announced or unannounced.
TMB Capital is required to periodically update the information provided to these agencies and to provide various
reports regarding the business activities and assets of the Advisor.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 30
Form ADV Part 2B – Brochure Supplement
for
Zachary G. Sokora
Vice President
Effective: February 4, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Zachary
G. Sokora (CRD# 7162495) in addition to the information contained in the TMB Capital Partners, LLC (“TMB Capital”
or the “Advisor”, CRD# 335750) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or
if you have any questions about the contents of the TMB Capital Disclosure Brochure or this Brochure Supplement,
please contact us at 501-671-1140.
Additional information about Mr. Sokora is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7162495.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 31
Item 2 – Educational Background and Business Experience
Zachary G. Sokora, born in 1996, is dedicated to advising Clients of TMB Capital as a Vice President. Mr. Sokora
earned his Bachelor’s Degree in Finance from the University of Arkansas in 2019. Additional information regarding
Mr. Sokora’s employment history is included below.
Employment History:
Vice President, TMB Capital Partners, LLC
Financial Advisor, Raymond James & Associates, Inc.
Institutional Equity Sales, Stephens Inc.
Investment Sales Officer I, BOK Financial Securities, Inc.
07/2025 to Present
05/2024 to 07/2025
09/2022 to 05/2024
08/2019 to 09/2022
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Sokora. Mr. Sokora has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Sokora.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud;
false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or
extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or
disciplinary events to disclose regarding Mr. Sokora.
However, we do encourage you to independently view the background of Mr. Sokora on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
7162495.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Sokora is also a licensed insurance professional. Implementations of insurance recommendations are separate
and apart from Mr. Sokora’s role with TMB Capital. As an insurance professional, Mr. Sokora will receive customary
commissions and other related revenues from the various insurance companies whose products are sold. Mr. Sokora
is not required to offer the products of any particular insurance company. Commissions generated by insurance sales
do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of
the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Sokora
or the Advisor. Mr. Sokora spends approximately 10% of his time per month in this capacity.
The Big Short LLC
Mr. Sokora also serves as a Partner of The Big Short LLC, which owns a rental property in Arkansas. Mr. Sokora is
compensated and spends less than 5% of his time per month in this capacity.
Item 5 – Additional Compensation
Mr. Sokora has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Sokora serves as a Vice President of TMB Capital and is supervised by Scott Tabor, the Chief Compliance
Officer. Mr. Tabor can be reached at 501-671-1140.
TMB Capital has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of TMB Capital. Further, TMB Capital is subject to regulatory
oversight by various agencies. These agencies require registration by TMB Capital and its Supervised Persons. As
a registered entity, TMB Capital is subject to examinations by regulators, which may be announced or unannounced.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 32
TMB Capital is required to periodically update the information provided to these agencies and to provide various
reports regarding the business activities and assets of the Advisor.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 33
Privacy Policy
Effective: February 4, 2026
Our Commitment to You
TMB Capital Partners, LLC (“TMB Capital” or the “Advisor”) is committed to safeguarding the use of personal
information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as
described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your private
information, and we do everything that we can to maintain that trust. TMB Capital (also referred to as "we", "our" and
"us”) protects the security and confidentiality of the personal information we have and implements controls to ensure
that such information is used for proper business purposes in connection with the management or servicing of our
relationship with you.
TMB Capital does not sell your non-public personal information to anyone. Nor do we provide such information to
others except for discrete and reasonable business purposes in connection with the servicing and management of
our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth
in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how
we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number
Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal information
and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s
personal information.
We require third parties that assist in providing our services to you to protect the personal information they receive
from us.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
Page 34
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
to: processing
No
Not Shared
Yes
Yes
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide agreed
upon services to you, consistent with applicable law, including but not
limited
transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
Marketing Purposes
TMB Capital does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with financial
institutions where you are a customer and where TMB Capital or the client
has a formal agreement with the financial institution. We will only share
information for purposes of servicing your accounts, not for
marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and persons
that we believe to be your authorized agent[s] or representative[s].
No
Not Shared
Information About Former Clients
TMB Capital does not disclose and does not intend to disclose, non-public
personal information to non-affiliated third parties with respect to persons
who are no longer our Clients.
SMS Messaging
The Advisor’s SMS messaging provides the Client with timely and relevant communications directly from the Advisor.
Clients can expect to receive periodic messages that may include notifications about upcoming meetings, responses
to inquiries, and important account-related information. These messages are sent via an SMS application, where all
sensitive data is delivered securely, to maintain the confidentiality and integrity of the Client’s data. Please note that
the frequency and content of these messages will be related to the services to the Client. SMS opt-in or phone
numbers for the purpose of SMS are not shared with any third parties or affiliate companies for marketing purposes.
The Advisor will never share, sell, or trade your personal information, including phone numbers and SMS consent,
with any third parties under any circumstances.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal
information other than as described in this notice unless we first notify you and provide you with an opportunity to
prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting
us at 501-671-1140.
TMB Capital Partners, LLC
2226 Cottondale Lane, STE 110, Little Rock, AR 72202
Phone: 501-671-1140
http://www.tmbcapitalpartners.com
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