Overview
- Headquarters
- Scottsdale, AZ
- Average Client Assets
- $2.2 million
- SEC CRD Number
- 108818
Fee Structure
Primary Fee Schedule (2025 TIM BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $250,000 | 1.30% |
| $250,001 | $1,000,000 | 1.00% |
| $1,000,001 | $2,000,000 | 0.75% |
| $2,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,750 | 1.08% |
| $5 million | $33,250 | 0.66% |
| $10 million | $58,250 | 0.58% |
| $50 million | $258,250 | 0.52% |
| $100 million | $508,250 | 0.51% |
Clients
- HNW Share of Firm Assets
- 64.75%
- Total Client Accounts
- 2,079
- Discretionary Accounts
- 1,935
- Non-Discretionary Accounts
- 144
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection
Regulatory Filings
Additional Brochure: FIRM BROCHURE (2026-03-16)
View Document Text
Firm Brochure
March 16, 2026
Firm Contact:
Brett Pohl
Chief Compliance Officer
Investment Management,
Inc.
is available on
This brochure provides information about the qualifications and business practices of Total Investment
Management, Inc. (“TIM”). If you have any questions about the contents of this brochure, please contact
Christopher Payne at 513-399-8091. The information in this brochure has not been approved or verified by the
United States Securities and Exchange Commission (SEC) or by any state securities authority. Additional
information about Total
the SEC’s website at
www.adviserinfo.sec.gov.
Total Investment Management, Inc. is an SEC registered investment adviser. Registration does not imply any level
of skill or training.
9383 East Bahia Drive, Suite 120, Scottsdale, AZ 85260 | (480) 998-5735
www.timgt.com
Page | 1
Item 2. Material Changes
There have been no material changes to this Disclosure Brochure since the last annual amendment on March 25,
2025. We have made certain non-material edits (such as clarifications, formatting, and typographical corrections)
that do not affect the substance of the information provided.
You may always request a complete copy of the most up-to-date version of this brochure by contacting TIM’s
Chief Compliance Officer by email at compliance@timgt.com.
Additional information about Total Investment Management, Inc. is available via the SEC’s website
www.adviserinfo.sec.gov.
Page | 2
Item 3. Table of Contents
Item 2. Material Changes................................................................................................................................................................ 2
Item 3. Table of Contents .............................................................................................................................................................. 3
Item 4. Advisory Business .............................................................................................................................................................. 4
Item 5. Fees and Compensation ................................................................................................................................................... 6
Item 6. Performance-Based Fees and Side-by-Side Management .......................................................................................... 9
Item 7. Types of Clients ................................................................................................................................................................. 9
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ................................................................................. 9
Item 9. Disciplinary Information ................................................................................................................................................ 13
Item 10. Other Financial Industry Activities and Affiliations ................................................................................................ 13
Item 11. Code of Ethics ................................................................................................................................................................ 14
Item 12. Brokerage Practices....................................................................................................................................................... 15
Item 13. Review of Accounts ...................................................................................................................................................... 17
Item 14. Client Referrals and Other Compensation ............................................................................................................. 17
Item 15. Custody ............................................................................................................................................................................ 19
Item 16. Investment Discretion .................................................................................................................................................. 20
Item 17. Voting Client Securities ................................................................................................................................................ 20
Item 18. Financial Information ..................................................................................................................................................... 20
Page | 3
Item 4. Advisory Business
TIM provides financial planning and investment management services through a series of asset management
platform offerings. Prior to engaging TIM to provide any of the foregoing investment advisory services, the client
is required to enter into one or more written agreements with TIM, setting forth the terms and conditions under
which TIM renders its services (collectively the “Agreement”).
TIM has been in business since 1998 and is principally owned by John Edward Foster II and Todd Michael Foster.
As of December 31, 2025, the firm had $1,352,142,086 in assets under management. Although TIM offers non-
discretionary services, that vast majority of its assets were managed on a discretionary basis (92%).
This Disclosure Brochure describes the business of TIM. Certain sections will also describe the activities of
Supervised Persons. Supervised Persons are any of TIM’s officers, partners, directors (or other persons occupying a
similar status or performing similar functions), or employees, or any other person who provides investment
advice on TIM’s behalf and is subject to TIM’s supervision or control.
Financial Planning and Consulting Services
TIM offers its clients a broad range of comprehensive financial planning services. Income tax preparation services
are available from an independent tax and accounting firm. These services are only offered to certain ongoing
investment management clients, as described below.
Investment Management Services
Clients can engage TIM to manage all or a portion of their assets on a discretionary basis. The firm offers
three different levels of investment management services, which are discussed below:
• TIM Basic - This is a service where clients have TIM manage their employer-sponsored retirement plans.
TIM Basic is only available to clients who are unable to take fees out of their employer-sponsored
retirement accounts and is the only service these clients are able to select. Under this program, the Firm
offers one actively traded investment model portfolio, which generally consists of mutual funds and
exchange-traded funds (“ETFs”). The program also consists of weekly commentary and weekly webcasts
and is targeted to aviation professionals designed to give them an understanding of their employer-
sponsored retirement plans. For clients who wish to subscribe to TIM’s commentary and webcast
and receive model portfolio trade allocations but retain the authority to trade their accounts, TIM offers
a Basic subscription service with allocations but no investment supervisory or investment management
services. Moreover, the Firm’s investment professionals are available to clients in this program to answer
any questions. This program does not include financial planning, and clients are able to engage the firm
for financial planning at an additional fee.
• TIM Portfolio - The Firm has a more enhanced offering to TIM Basic, known as “TIM Portfolio,” which is a
more comprehensive investment management program. TIM Portfolio is available to clients whose
employer airlines are able to take fees out directly from their employer-sponsored retirement accounts.
TIM Portfolio is also available for a variety of accounts including Individual Retirement Accounts (IRAs),
trust accounts, individual and joint accounts, and other accounts that TIM may accept in its discretion for
investment management services. TIM Portfolio includes all the same benefits as TIM Basic but offers
clients the opportunity to invest in one of the five model portfolios, which generally consist of mutual
funds and ETFs, and are managed by the Firm based on the client’s age and risk tolerance. In addition,
while TIM’s advisers are available to answer questions, TIM Portfolio clients also have one scheduled
annual checkup call per year with the Firm to discuss developments in their financial situations. This
program does not include financial planning, and clients are able to engage the firm for financial planning
at an additional fee.
• TIM Premier - The Firm’s most encompassing service offering is TIM Premier, which offers clients a more
robust wealth management platform that includes all the services of TIM Portfolio. TIM Premier is
available to clients whose employer airlines are able to take fees out directly from their employer-
sponsored retirement accounts. TIM Premier is also available for a variety of accounts including
Individual Retirement Accounts (IRAs), trust accounts, individual and joint accounts, and other accounts
that TIM may accept in its discretion for investment management services. While the model portfolios
available to TIM Premier clients are generally comprised of mutual funds and ETFs, TIM may incorporate
other types of securities into TIM Premier client accounts, as appropriate for the client’s investment
objectives. Moreover, in addition to receiving a scheduled annual call to review their financial plan, TIM
Premier clients also receive scheduled quarterly check-in calls. TIM Premier offers clients financial planning,
insurance needs analysis, tax preparation provided by an independent tax and accounting firm (discussed
in Item 14), estate planning consultation provided by an independent law firm (discussed in Item 14), and
social security optimization services, which are included in the overall fee.
Clients are advised to promptly notify TIM if there are changes in their financial situation or investment
objectives or if they wish to impose any reasonable restrictions upon TIM’s management services. TIM Portfolio
and Premier clients can impose reasonable restrictions on the management of their account if, in TIM’s sole
discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly
burdensome to its management efforts.
Information Regarding Potential Conflicts of Interest
Although we seek to avoid them, our firm has actual or potential conflicts of interest arising from our advisory
services. These include, but are not limited to:
• Conflicts related to allocating time and resources between client accounts, allocation of brokerage
commissions and investment opportunities generally. For further information on our brokerage and
allocation policies, and related conflicts of interest, please refer to Item 12 below.
• Conflicts related to asset-based fees. At times our investment professionals will recommend that a client
move assets from another investment account to one managed by our firm. This would result in a higher
total advisory fee for that investment professional and generate revenue for the firm. See the disclosure
in Item 4 discussing the recommendation of rollovers and transfers to TIM for more information. There
is a conflict of interest whenever we encourage clients to move their assets to our firm. For further
information, please refer to Item 5 which discusses the fees we earn when providing advisory services.
• Conflicts related to investing in securities recommended to clients and contemporaneous trading of
securities (i.e., personal trading) by the firm and its related persons. Please refer to Item 11 for further
information.
• Conflicts related to third parties. When appropriate, we will recommend third parties to advise a client
on matters including but not limited to: legal, tax or accounting advice. These recommendations are
sometimes made because of existing relationships our firm and its employees have with these groups or
individuals. We do not currently have any formal solicitor or referral arrangements.
Actual or potential conflicts of interest generally can be addressed in several ways, including prohibiting the
conduct that gives to the conflict of interest, implementing procedures to prevent a person from gaining or
utilizing knowledge that potentially give rise to a conflict; establishing parameters for conduct that are designed
to protect client interests or limit the benefit that creates the conflict of interest, or disclosing the conflict of
interest to our clients.
Our firm has adopted a Code of Ethics. (Please refer to Item 11 below for further information on our Code of
Ethics) and we also have policies and procedures in place to mitigate and address conflicts of interest. We
believe that such policies and procedures are reasonably designed to treat clients equitably and to advance the
best interests of the clients. The clients' best interest is paramount in any situation involving a conflict of
interest.
Recommending Rollovers and Transfers to TIM
Our firm has an inherent conflict of interest in recommending you rollover or transfer your accounts to an
account managed by us since we have an incentive to generate compensation for the firm.
When we provide investment advice to you regarding your retirement plan account or individual retirement
account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or
the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make
money creates some conflicts with your interests, so we operate under a special rule that requires us to act in
your best interest and not put our interest ahead of yours.
Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
It is important that you understand the differences between these types of accounts and to decide whether a
rollover is best for the client. Prior to proceeding, if you have any questions, please contact the firm’s Chief
Compliance Officer, or call TIM’s main number as listed on the cover page of this brochure.
Item 5. Fees and Compensation
TIM offers its services on a fee basis, which depending on the program selected, includes either fixed fees or fees
based upon assets under management. Additionally, certain of TIM’s Supervised Persons, in their individual
capacities, offer insurance products under a commission arrangement as they feel appropriate given the client’s
individual needs and circumstances.
Investment Management Fee (also referred to as “Advisory Fee”)
TIM’s annual Advisory Fee is exclusive of, and in addition to, brokerage commissions, transaction fees, and other
related costs and expenses that are incurred by the client, as discussed below. TIM does not, however, receive
any portion of these commissions, transaction fees, and costs. Fees are negotiable at TIM’s discretion.
TIM Basic
TIM Basic is a service where the Firm provides model portfolio trade allocations, weekly commentary, and weekly
webcasts targeted to aviation professionals.
For clients who engage the Firm for TIM Basic, TIM charges an annual fee of $625 for pilots and $315 for flight
attendants and ground personnel. This fee is paid annually, in advance.
For TIM Basic clients who also have additional i-Shares-only, Municipal Bond-only, or Annuity accounts managed
by TIM, TIM charges an annual asset based advisory fee which is prorated and billed quarterly in advance,
based on the market value of the assets on the last day of the prior quarter. The current annual fee schedule for
these account types is: iShares-only accounts: .25% ; Municipal Bond-only accounts: .25% ; For Ameritas annuity
accounts (where TIM provides investment advice with respect to subaccounts or allocation decisions) the fee is
.25% for Portfolio clients and is charged based on the Premier tiered fee below. These fees are negotiable and are
described in the client agreement and/or schedule provided at account opening.
TIM Portfolio
TIM Portfolio is an investment management program that includes the TIM Basic benefits and provides clients
access to one of the Firm’s model portfolios based on age and risk tolerance. Clients also receive one scheduled
annual checkup call to discuss developments in their financial situation. TIM Portfolio does not include financial
planning, which is available for an additional fee (see “Additional Fees” below)
For TIM Portfolio clients, the firm charges an flat annual asset-based fee of 0.25% of the value of the assets
under management. This annual fee is prorated and charged quarterly, in advance, based upon the market value of
the assets being managed by TIM on the last day of the previous quarter.
PORTFOLIO VALUE
All Assets Under Management
BASE FEE
0.25%
TIM Premier
TIM Premier is the Firm’s most encompassing offering. It includes the services of TIM Portfolio, may incorporate
other types of securities as appropriate for client objectives, and includes scheduled quarterly check-in calls and
financial planning. TIM Premier also includes insurance needs analysis and certain coordinated services provided
by independent third parties (e.g., tax preparation and estate planning consultation), as further discussed in Item
14.
For TIM Premier clients, the Firm charges an annual asset-based fee that includes various financial planning services
as discussed above in Item 4. This Fee is prorated and charged quarterly, in advance, based upon the market value
of the assets being managed by TIM on the last day of the previous quarter. This annual fee varies depending upon
the market value of the assets under TIM’s management as follows:
PORTFOLIO VALUE
Up to $250,000
$250,000.01 - $1,000,000
$1,000,000.01 - $2,000,000
above $2,000,000.01
BASE FEE
1.30%
1.00%
0.75%
0.50%
TIM aggregates household accounts to determine the lowest percentage if all accounts are managed as one
relationship.
Because clients may receive similar advice or model allocations while paying different fees, the Firm has a conflict
of interest to recommend higher-fee programs or allocate more time and attention to higher-fee relationships.
The Firm addresses this conflict by disclosing material program differences and fees, basing program
recommendations on client needs and requested scope, applying a consistent investment process, documenting
and supervising program recommendations and any negotiated fees, and periodically reviewing whether the
selected program remains appropriate.
Financial Planning Fees
For TIM Basic and TIM Portfolio clients, TIM charges a fixed fee for preparation of a financial plan ($2,250) and
review of a financial plan ($500). As discussed above, these financial services are included for TIM Premier clients
at no additional fee.
Prior to engaging TIM to provide financial planning, the client is required to enter into a written agreement
with TIM setting forth the terms and conditions of the engagement. TIM does not require payment until
completion of these services.
Additional Fees and Expenses
In addition to the advisory fees paid to TIM, clients also incur certain charges imposed by other third parties,
such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial
Institutions”). These additional charges can include securities brokerage commissions, transaction fees, custodial
fees, charges imposed directly by a mutual fund or ETF in a client’s account as disclosed in the fund’s prospectus
(e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes,
wire transfer and electronic fund fees and other fees and taxes on brokerage accounts and securities
transactions. The Firm’s brokerage practices are described at length in Item 12, below.
Fee Debit
Clients generally provide TIM with the authority to directly debit their accounts for payment of the Firm’s
investment advisory fees. The Financial Institutions that act as qualified custodian for client accounts have agreed
to send statements to clients not less often than quarterly detailing all account transactions, including any amounts
paid to TIM. Alternatively, clients can elect to have TIM send them an invoice for direct payment.
Fees for Management During Partial Quarters of Service
For the initial period of investment management services, the fees are calculated on a pro rata basis. The Agreement
between TIM and the client will continue in effect until terminated by either party pursuant to the terms of the
Agreement. TIM’s fees are prorated through the date of termination and any remaining balance is charged or
refunded to the client, as appropriate.
Clients may make additions to and withdrawals from their account at any time, subject to TIM’s right to terminate
an account. Additions may be in cash or securities provided that TIM reserves the right to liquidate any
transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw
account assets on notice to TIM, subject to the usual and customary securities settlement procedures.
However, TIM designs its portfolios as long-term investments, and the withdrawal of assets could impair the
achievement of a client’s investment objectives. If notified in advance, TIM will consult with its clients about
the options and ramifications of transferring securities. However, clients are advised that when transferred
securities are liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e.
contingent deferred sales charge) and/or tax ramifications.
If assets are deposited into or withdrawn from an account after the inception of a quarter for TIM Portfolio or
TIM Premier clients, the fee payable with respect to such assets will be adjusted or prorated based on the number
of days remaining in the quarter. TIM Basic clients pay a fixed annual fee regardless of the amount of assets
under management, and as such no adjustments are made based on inflows to or outflows from the account.
Item 6. Performance-Based Fees and Side-by-Side Management
TIM does not provide any services for performance-based fees. Performance-based fees are those based on a
share of capital gains on or capital appreciation of the assets of a client.
The Firm offers clients different advisory programs with different service levels and fee arrangements, including
TIM Basic (non-discretionary; clients implement and monitor their own accounts), TIM Portfolio (model-portfolio
access for an annual asset-based fee), and TIM Premier (investment management and financial planning for a tiered
asset-based fee).
Because clients may receive similar advice or model allocations while paying different fees, the Firm has a conflict
of interest to recommend higher-fee programs or allocate more time and attention to higher-fee relationships.
The Firm addresses this conflict by disclosing material program differences and fees, basing program
recommendations on client needs and requested scope, applying a consistent investment process, documenting
and supervising program recommendations and any negotiated fees, and periodically reviewing whether the
selected program remains appropriate
Item 7. Types of Clients
TIM primarily provides its services to individuals, including high net worth individuals.
Minimum Fee
For TIM Portfolio and TIM Premier clients, TIM generally imposes a minimum annual fee of $600. TIM, in its sole
discretion, may waive its minimum annual fee based upon certain criteria including anticipated future earning
capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account
composition, pre-existing client, account retention, and pro bono activities.
Item 8. Methods of Analysis, Investment Strategies and Risk of
Loss
Methods of Analysis
TIM’s primary methods of analysis include aspects of fundamental and technical analysis.
Fundamental analysis involves the fundamental financial condition and competitive position of a company. TIM
will analyze the financial condition, capabilities of management, earnings, new products and services, as well as the
company’s markets and position amongst its competitors in order to determine the recommendations made
to clients. The primary risk in using fundamental analysis is that while the overall health and position of a company
may be good, market conditions may negatively impact the shares of the company.
Technical analysis involves the analysis of past market data rather than specific company data in determining the
recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns
and trends which may be based on investor sentiment rather than the fundamentals of the company. More
specifically, the firm may rely on charting, where the firm reviews charts of market and security activity in an
attempt to identify when the market is moving up or down, to predict how long the trend will last and when
it might reverse. The primary risk in using technical analysis is that spotting historical trends may not help to
predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that TIM will
be able to accurately predict such a reoccurrence.
Investment Strategies
As further explained in its response to Item 4, the firm offers three different asset management programs: TIM
Basic. TIM Portfolio, and TIM Premier. All three programs offer investors the ability to invest in one or more of the
firm’s proprietary model portfolios (the number of available portfolios depends on the program).
TIM follows a proactive tactical asset allocation strategy to manage portfolios. The firm closely monitors its
holdings for relative performance, following economic and technical indicators and using a strict risk management
discipline. There will be times where portfolio turnover will increase with volatility. Overall, the firm seeks to
keep turnover low while maintaining returns.
Using this strategy, the firm allocates its model portfolios among several asset classes, including small caps, mid-
caps, large-caps, international and bonds. The firm starts with an appropriate asset allocation according to
the client’s risk tolerance, age and goals and then adjusts the allocations as it sees fit. This strategy allows TIM
to be overweight in asset classes it feels will outperform, and to underweight those it feels will underperform.
Rebalancing is used to take profits on positions when the firm feels the market is approaching a short-term
opportunity.
As indicated above, TIM portfolios are generally managed utilizing a combination of strategic and tactical asset
allocation strategies. Clients generally work with the firm to create an investor policy statement (IPS) to set the
strategic mix of assets for inclusion in the client's holdings. The percentage of weighting that each asset class has
over the long term is known as the strategic asset allocation. This allocation is the mix of assets and weights that
help an investor reach their specific goals over the long term. Tactical asset allocation is an active management
portfolio strategy that shifts the percentage of assets held in various categories to take advantage of market pricing
anomalies or strong market sectors. The result of TIM’s choice to take an active stance on the strategic asset
allocation itself means that your target weight for certain assets may drift from the original asset allocation for
short periods of time to allow the firm to capitalize on the market or economic opportunities.
TIM has a basket of indicators it uses to help identify long term trend changes. If the long-term trend turns
down, TIM downshifts the portfolios by selling certain holdings for a more conservative posture. Once the
firm’s indicators have pointed to a sustainable market “uptrend”, TIM will reinvest according to the agreed
allocation.
TIM primarily allocates assets within the model portfolios among mutual funds and ETFs. For TIM Premier clients,
TIM also offers clients the opportunities to invest in other types of securities, depending on the client’s individual
objectives.
As part of its management philosophy, the firm uses the following strategies:
•
Long term purchases: The firm may rely on this technique when it believes securities to be currently
undervalued and/or it wants exposure to a particular asset class over time (regardless of the current
projection for that class). These securities are typically purchased with the idea of holding them in
a client’s account for a year or longer.
• Short term purchases: When TIM uses this strategy, the firm purchases securities with the intention of
selling them within a year. TIM employs this technique when it believes that conditions will result in
a price swing in the securities purchased. This strategy can result in more frequent trading, which in turn
can raise the brokerage costs incurred by the client.
Risks of Loss
General Risk of Loss
Investing in securities involves the risk of loss. Clients should be prepared to bear such loss.
Market Risks
The profitability of a significant portion of TIM’s recommendations may depend to a great extent upon correctly
assessing the future course of price movements of stocks and bonds. There can be no assurance that TIM will
be able to predict those price movements accurately.
Risks Associated with Tactical Asset Allocation Strategies
Tactical asset allocation is an active management portfolio strategy that shifts the percentage of assets held in
various categories to take advantage of market pricing anomalies or strong market sectors. This strategy
theoretically allows portfolio managers to create extra value by taking advantage of certain situations in the
marketplace. It is as a moderately active strategy since managers return to the portfolio's original strategic asset
mix once reaching the desired short-term profit.
Like all active management strategies, there is the risk that TIM strategies may underperform its benchmark or
the market if the portfolio manager does not correctly identify market opportunities, e.g., your portfolio may
overperform or underperform the market or the strategy’s benchmark depending on the portfolio’s manager
accuracy. Furthermore, in our efforts to outperform a benchmark and achieve higher returns for investors,
investors’ portfolios may deviate from the original risk characteristics and/or the portfolios benchmarks. No
strategy offered by our firm guaranteed positive results and past performance is not indicative of future results.
Mutual Funds and ETFs
An investment in a mutual fund or ETF (including i-Shares) involves risk, including the loss of principal. Mutual
fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s
underlying portfolio securities. Such shareholders also may be liable for taxes on any fund-level capital gains
received in taxable accounts, as mutual funds and ETFs are required by law to distribute capital gains in the event
that they sell securities for a profit that cannot be offset by a corresponding loss.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a
broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per
share net asset value (“NAV”), plus any shareholders’ fees (e.g., sales loads, purchase fees, redemption fees). The
per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV
fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s
shares may differ significantly from the NAV during periods of market volatility, which may, among other factors,
lead to the mutual fund’s shares trading at a premium or discount to NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market.
Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily
for indexed-based ETFs and more frequently for actively managed ETFs. However, certain inefficiencies may
cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that
an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems
shares when aggregated as creation units (usually 50,000 shares or more). Therefore, if a liquid secondary market
ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares.
Municipal Bonds
Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the
construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds.
However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax return
to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds
carries the same general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment
risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk.
Management Through Similarly Managed Accounts
TIM primarily manages portfolios by allocating portfolio assets among various securities on a discretionary basis
using one or more of its proprietary investment strategies (collectively referred to as “investment strategy”). In
so doing, TIM buys, sells, exchanges and/or transfers securities based upon the investment strategy.
TIM’s management using the investment strategy complies with the requirements of Rule 3a-4 of the Investment
Company Act of 1940, as amended. Rule 3a-4 provides similarly managed accounts, such as the investment
strategy, with a safe harbor from the definition of an investment company.
Securities in the investment strategy are usually exchanged and/or transferred without regard to a client’s
individual tax ramifications. Certain investment opportunities that become available to TIM’s clients may be
limited. As further discussed in response to Item 12B (below), TIM allocates investment opportunities among
its clients on a fair and equitable basis.
Risks Associated with Bitcoin-Based Strategies
A limited number of clients may be placed in separately managed accounts managed by an uaffiliated third-party
investment adviser that seeks to provide tactical exposure to bitcoin through an exchange traded product that
tracks a bitcoin index. Clients who participate may pay advisory fees to both TIM and the third party manager
(in addition to the ETF’s internal fees and expenses), which increases the overall cost of the arrangement. TIM
conducts due diligence on the third party manager and monitors the relationship on an ongoing basis, but TIM
does not control the day-to-day management decisions of the third party manager. Bitcoin is a digital
representation of value that functions as a medium of exchange, a unit of account, or a store of value, but it does
not have legal tender status. Bitcoin is not backed nor supported by any government or central bank. Bitcoin’s
price is completely derived by market forces of supply and demand, and it is more volatile than traditional
currencies and financial assets. Investing in bitcoin-linked products, involves significant risks, including volatility,
regulatory, market structure, , economic, technical, and cybersecurity risks, and bitcoin markets and venues may
not provide the same protections as traditional securities markets.
• Volatility Risk: Bitcoin is a speculative and volatile investment asset. Investors should be prepared for
volatile market swings and prolonged bear markets. Bitcoin can have higher volatility than other
traditional investors such as stocks and bonds.
• Economic Risk: The economic risk associated with bitcoin is in the lack of widespread or continuing
bitcoin adoption. The market and investors could decide that bitcoin should not be valued at the current
market capitalization due to a variety of factors.
• Regulatory Risk: Bitcoin could be banned or highly regulated by governments that would deter investors
from buying or holding bitcoin.
• Technical Risk: Bitcoin is a dynamic network with a codebase that is updated to add new security and
functionality features. The updated code that is merged by the core developers could potentially have an
error that threatens the security or functionality of the bitcoin network.
• Cybersecurity Risk: Bitcoin exchanges and wallets have been hacked and bitcoin has been stolen in the
past. Although this does not impact people participating in the strategy since you will not be invested in
bitcoin directly, this is a potential risk that bitcoin holders must be comfortable with when investing and
holding bitcoin, and a widespread cybersecurity incident could impact the bitcoin market and cause
significant price fluctuations.
Item 9. Disciplinary Information
TIM is required to disclose the facts of any legal or disciplinary events that are material to a client’s evaluation of
its advisory business or the integrity of management. TIM does not have any required disclosures to this Item.
Item 10. Other Financial Industry Activities and Affiliations
TIM is required to disclose any relationship or arrangement that is material to its advisory business or to its
clients with certain related persons. TIM has described such relationships and arrangements below.
Affiliated Investment Adviser
TIM is under common control with its affiliated SEC registered investment adviser, RESQ Investment Partners,
LLC (“RESQ Investment Partners”) (SEC File No. 801-78822). Certain Supervised Persons of TIM also serve as
portfolio managers for RESQ Investment Partners, which is the investment adviser to the RESQ Strategic Income
Fund and the RESQ Dynamic Allocation Fund (the “RESQ Funds”).
Because of this affiliation, a conflict of interest exists when TIM invests client assets in the RESQ Funds. Specifically,
TIM’s affiliate, RESQ Investment Partners, receives compensation for advisory services provided to the RESQ
Funds, and TIM and/or its affiliates and certain Supervised Persons may receive indirect economic benefits to the
extent client assets are invested in the RESQ Funds (including through advisory fees paid at the fund level). This
financial incentive could create a conflict between TIM’s interests and those of its clients.
Clients are not required to invest in the RESQ Funds. Pursuant to the Investment Management Agreement (IMA)
and on a fully disclosed basis, clients may limit TIM’s authority to invest assets into the RESQ Funds . .
To the extent that client assets are invested in the RESQ Funds, clients do not pay a “dual” fee because TIM
does not charge its investment management fee on any such assets invested in the RESQ Funds. While TIM
and/or its Supervised Persons are indirectly compensated based on its or their affiliation with RESQ Investment
Partners, which receives an advisory fee for services provided to the RESQ Funds, the firm does not believe
this arrangement poses any additional material conflict of interest.
TIM seeks to mitigate this conflict by applying the same due diligence and ongoing monitoring process to the
RESQ Funds that it applies to unaffiliated investment options, including considering reasonably available
alternatives and periodically reviewing RESQ Fund investments for continued appropriateness.
Information about how RESQ Investment Partners is compensated by the RESQ Funds is available in funds’
prospectus.
Affiliated Broker Dealer
TIM is under common control with, and certain principals (Todd Foster, John Greer, and Bryan Lee) maintain
passive ownership of, a FINRA registered broker dealer, Vision 4 Fund Distributors (“Vision 4”), member
FINRA/SIPC. Vision 4 acts as a distributor for certain mutual funds and may receive compensation in that capacity
(e.g., distribution and or servicing-related compensation. This affiliation creates a conflict of interest to the extent
TIM recommends mutual funds or other products for which Vision 4 serves as distributor, because Vision 4 may
benefit financially from client investments in those products. Clients are not required to purchase and products
through, or distributed by, Vision 4 and TIM considers reasonably available alternatives when making
recommendations. TIM endeavors always to put the interest of its clients first as part of our fiduciary duty..
From time to time, TIM recommends mutual funds for which Vision 4 serves as distributor; in those circumstances,
Vision 4 generally will waive any distributor compensation that would otherwise be payable in connection with a
client’s purchase through Vision 4, although Vision 4 may still receive other forms of compensation permitted in
its distributor capacity depending on the product and share class.
TIM can provide additional information regarding this affiliation and related conflicts upon request.
Receipt of Insurance Product Commissions
Certain of TIM’s Supervised Persons, in their individual capacities, are also licensed insurance agents with various
insurance companies, and in such capacity, will recommend, on a fully disclosed commission basis, the purchase of
certain insurance products. While TIM does not sell such insurance products to its investment advisory clients,
TIM does permit its Supervised Persons, in their individual capacities as licensed insurance agents, to sell insurance
products to its investment advisory clients. A conflict of interest exists to the extent that TIM recommends
the purchase of insurance products where TIM’s Supervised Persons receive insurance commissions or other
additional compensation.
We require representatives to disclose all outside business activities to our compliance team, and we evaluate
whether such activities impair their ability to serve our clients objectively.
Item 11. Code of Ethics
TIM and persons associated with TIM (“Associated Persons”) are permitted to buy or sell securities that it
also recommends to clients consistent with TIM’s policies and procedures. TIM has adopted a code of ethics
that sets forth the standards of conduct expected of its associated persons and requires compliance with
applicable securities laws (“Code of Ethics”). TIM’s Code of Ethics contains written policies reasonably
designed to prevent the unlawful use of material non-public information by TIM or any of its associated persons.
The Code of Ethics also requires that certain of TIM’s personnel (called “Access Persons”) report their
personal securities holdings and transactions and obtain pre-approval of certain investments such as initial
public offerings and limited offerings.
When TIM is engaging in or considering a transaction in any security on behalf of a client, no Access Person
may effect for themselves or for their immediate family (i.e., spouse, minor children, and adults living in the
same household as the Access Person) a transaction in that security unless:
•
•
•
the transaction on behalf of the client has been completed;
the transaction for the Access Person is completed as part of a batch trade (as defined below in Item
12)
with clients; or
a decision has been made not to engage in the transaction for the client.
These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii)
money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase
agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares
issued by mutual funds or money market funds; and (iv) shares issued by unit investment trusts that are invested
exclusively in one or more mutual funds.
This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets
to permit transactions by Access Persons to be completed without any appreciable impact on the markets of
such securities. Therefore, under certain limited circumstances, exceptions may be made to the policies stated
above. Clients and prospective clients may contact TIM to request a copy of its Code of Ethics by
contacting TIM’s Chief Compliance Officer at timcompliance@timgt.com.
Item 12. Brokerage Practices
TIM generally recommends that clients utilize the brokerage and clearing services of Charles Schwab & Co., Inc.
(“Schwab”) and/or Fidelity Institutional Wealth Services (“Fidelity”) for investment management accounts.
Factors which TIM considers in recommending Schwab, Fidelity, or any other broker-dealer to clients include their
respective financial strength, reputation, execution, pricing, research and service. Schwab and Fidelity enable TIM
to obtain many mutual funds without transaction charges and other securities at nominal transaction charges.
The commissions and/or transaction fees charged by Schwab and Fidelity may be higher or lower than those
charged by other Financial Institutions.
The commissions paid by TIM’s clients comply with TIM’s duty to obtain “best execution.” Clients may pay
commissions that are higher than another qualified Financial Institution might charge to effect the same transaction
where TIM determines that the commissions are reasonable in relation to the value of the brokerage and
research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but
whether the transaction represents the best qualitative execution, taking into consideration the full range of
a Financial Institution’s services, including among others, the value of research provided, execution capability,
commission rates, and responsiveness. TIM seeks competitive rates but may not necessarily obtain the lowest
possible commission rates for client transactions.
TIM periodically and systematically reviews its policies and procedures regarding its recommendation of Financial
Institutions considering its duty to obtain best execution. The client may direct TIM in writing to use a particular
Financial Institution to execute some or all transactions for the client. In that case, the client will negotiate terms
and arrangements for the account with that Financial Institution, and TIM will not seek better execution services
or prices from other Financial Institutions or be able to “batch” client transactions for execution through other
Financial Institutions with orders for other accounts managed by TIM (as described below). As a result, the client
may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices,
on transactions for the account than would otherwise be the case. Subject to its duty of best execution, TIM
may decline a client’s request to direct brokerage if, in TIM’s sole discretion, such directed brokerage
arrangements would result in additional operational difficulties.
Transactions for each client generally will be effected independently, unless TIM decides to purchase or sell
the same securities for several clients at approximately the same time. TIM may (but is not obligated to)
combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates, or to
allocate equitably among TIM’s clients differences in prices and commissions or other transaction costs that
might not have been obtained had such orders been placed independently. Under this procedure, transactions
will generally be averaged as to price and allocated among TIM’s clients pro rata to the purchase and sale orders
placed for each client on any given day. To the extent that TIM determines to aggregate client orders for
the purchase or sale of securities, including securities in which TIM’s Supervised Persons may invest, TIM
generally does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance
provided by the staff of the U.S. Securities and Exchange Commission. TIM does not receive any additional
compensation or remuneration as a result of the aggregation. In the event that TIM determines that a prorated
allocation is not appropriate under the particular circumstances, the allocation will be made based upon other
relevant factors, which may include: (i) when only a small percentage of the order is executed, shares may be
allocated to the account with the smallest order or the smallest position or to an account that is out of line with
respect to security or sector weightings relative to other portfolio, with similar mandates; (ii) allocations may be
given to one account over another account that has limitations in its investment guidelines that prohibit it from
purchasing the security being allocated; (iii) if an account reaches an investment guideline limit and cannot
participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes
in an account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to
accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis
allocation in one or more accounts, TIM may exclude the account(s) from the allocation and allocate the shares
on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is
executed in all accounts, shares may be allocated to one or more accounts on a random basis.
In some situations, we may be unable aggregate orders for all clients participating in a certain TIM strategy at the
same time. For example, clients that participate in the same model at Fidelity and/or Schwab will be unable to
have orders executed in the same block trade without the use of a prime broker. In these situations, we utilize a
trade rotation strategy where we alternate between the broker/dealers. By employing this methodology, we seek
to treat all accounts participating in a similar strategy fairly and equitably over time.
Consistent with obtaining best execution, brokerage transactions may be directed to certain broker-dealers in
return for investment research products and/or services which assist TIM in its investment decision-making
process. Such research generally will be used to service all of TIM’s clients, but brokerage commissions paid by
one client may be used to pay for research that is not used in managing that client’s portfolio. The receipt of
investment research products and/or services as well as the allocation of the benefit of such investment research
products and/or services poses a conflict of interest because TIM does not have to produce or pay for the products
or services.
Software and Support Provided by Financial Institutions
TIM receives access from Schwab and Fidelity, without cost to TIM, computer software and related systems
support, which allow TIM to better monitor client accounts maintained at the respective custodian. TIM
receives access to the software and related support without cost because TIM renders investment management
services to clients that maintain assets at Schwab and Fidelity. The software and related systems support benefits
TIM, but not its clients directly. In fulfilling its duties to its clients, TIM endeavors at all times to put the interests
of its clients first. Clients should be aware, however, that TIM’s receipt of economic benefits from a broker-dealer
creates a conflict of interest since these benefits may influence TIM’s choice of broker-dealer over another
broker-dealer that does not furnish similar software, systems support, or services.
Additionally, TIM receives the following benefits from Schwab and Fidelity through their institutional divisions:
receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk that
exclusively services the respective institutional participants; access to block trading which provides the ability
to aggregate securities transactions and then allocate the appropriate shares to client accounts; and access to an
electronic communication network for client order entry and account information.
Item 13. Review of Accounts
TIM monitors clients’ portfolios as part of an ongoing process while regular account reviews are conducted on
at least a quarterly basis for Premier clients and annually for Portfolio clients. For those clients to whom TIM
provides financial planning and/or consulting services, reviews are conducted on an “as needed” basis, or annually
for TIM Premier clients. Such reviews are conducted by one of TIM’s CFPs®. All investment advisory clients
are encouraged to discuss their needs, goals, and objectives with TIM and to keep TIM informed of any changes
thereto. TIM contacts ongoing investment advisory clients at least annually to review its previous services and/or
recommendations and to discuss the impact of any changes in the client’s financial situation and/or investment
objectives.
Unless otherwise agreed upon, clients are provided with transaction confirmation notices and regular summary
account statements directly from the broker-dealer or custodian for the client accounts. On a quarterly basis,
TIM Premier clients will also receive a report from TIM that includes relevant account and/or market-related
information, such as an inventory of account holdings and account performance. Clients should compare the
account statements they receive from their custodian with those they receive from TIM. Those clients to whom
TIM provides financial planning and/or consulting services will receive reports from TIM summarizing its analysis
and conclusions upon request and as otherwise agreed to in writing by TIM.
Item 14. Client Referrals and Other Compensation
TIM is required to disclose arrangements under which it pays cash compensation to persons who refers clients to
TIM. TIM has entered into written referral agreements with certain third parties (“Referring Parties”) under
which TIM pays a cash referral fee if a referred individual becomes a TIM advisory client. Referral fees are by
TIM from its revenues (not as a separate charge to the client) and are 20% of the first years advisory fees actually
received by TIM from the referred client. The existence and terms of the referral agreement creates a conflict of
interest because the Referring Party has a financial incentive to recommend TIM.
When a client is referred to us by a referring party, the referring party provides the client with a copy of our Firm
Brochure as required by the Investment Advisers Act of 1940. The client will also complete a Solicitor’s Disclosure
Statement document. If the referring party is an unaffiliated registered investment adviser firm, then the client will
also receive a copy of the referring party’s Form ADV Part 2 Disclosure Brochure. If a referred client enters into
an investment management agreement with TIM, a referral fee is paid to the referring party. The referral
relationship will not result in clients being charged any fees over and above the normal advisory fees charged for
the advisory services provided. The referral agreements between TIM and referring parties are in compliance with
state and federal securities rules regarding paid solicitor arrangements.
TIM may receive economic benefits from non-clients for providing advice or other advisory services to clients.
This type of relationship poses a conflict of interest and any such relationship is disclosed in response to Item 12
(Brokerage Practices), above.
From time to time, TIM may receive marketing expense reimbursements or sponsorship support from distributors or
sponsors of investment products in connection with client education events or seminars (for example, a sponsor may
reimburse a portion of venue or meal costs). These arrangements create a conflict of interest because TIM has an incentive
to maintain relationships with sponsors that provide such support. TIM does not condition recommendations on
sponsorship, and TIM seeks to mitigate this conflict by (i) not permitting sponsors to influence investment advice, (ii)
selecting sponsors based on educational value and logistics rather than product recommendations, and (iii) evaluating
recommendations based on the client’s objectives and the merits of the investment.
Relationship with Sonoran Tax & Accounting, LLC
TIM maintains a relationship with Sonoran Tax & Accounting, LLC (“Sonoran”) whereby it refers certain of its
clients to Sonoran for tax preparation services and also directs its TIM Premier clients to Sonoran for basic
individual tax preparation as part of its overall service offering as discussed above in Item 4. While Sonoran
is independent of and unaffiliated with TIM, a conflict of interest exists, in the form of an indirect economic benefit,
to the extent that TIM and Sonoran refer their clients to one another and TIM may receive certain discounts for
Sonoran’s services relating to TIM clients.
The referral is provided solely as a convenience to the Client and does not constitute an endorsement, guarantee,
or representation by TIM as to the third party’s qualifications, competence, licensure, or performance. The Client
retains sole discretion and responsibility to select, engage, and oversee any tax preparer, including conducting any
diligence the Client deems appropriate.
The Client further acknowledges that TIM does not provide tax preparation services and does not prepare, sign,
file, review, audit, or otherwise verify any tax return, tax filing position, or other tax-related work product
prepared or performed by the third-party tax preparer. TIM does not assume, and expressly disclaims, any
responsibility or liability for the acts, errors, omissions, advice, recommendations, or services of any such third
party, including the accuracy or completeness of any tax returns or related documents
Relationship with Knollmiller & Arenofsky, LLP
TIM maintains a relationship with the independent, third-party law firm of Knollmiller & Arenofsky, LLP
(“Knollmiller”) whereby it directs its TIM Premier clients to Knollmiller for basic estate planning consultation as
part of its overall service offering as discussed above in Item 4. Knollmiller provides this consultation to TIM Premier
clients at no cost to TIM or the client. Should the client wish to proceed with an estate plan, the client
engages and pays the Knollmiller law firm directly for this service. While Knollmiller is independent of and
unaffiliated with TIM, a conflict of interest exists in the form of an indirect economic benefit, to the extent that
TIM and Knollmiller refer their clients to one another and TIM’s clients may request that TIM manage additional
account assets as identified in the actual estate planning process.
The referral is provided solely as a convenience to the Client and does not constitute an endorsement, guarantee,
or representation by TIM as to the third party’s qualifications, competence, licensure, or performance. The Client
retains sole discretion and responsibility to select, engage, and oversee any tax preparer, including conducting any
diligence the Client deems appropriate.
The Client acknowledges that TIM does not provide legal or estate planning services. Any estate planning work
(including drafting or reviewing wills, trusts, powers of attorney, or other legal documents) is performed solely by
an unaffiliated estate planning firm or attorney selected by the Client. TIM does not prepare, sign, file, review,
audit, or otherwise verify any estate planning documents or legal work product, and expressly disclaims any
responsibility or liability for the acts, errors, omissions, advice, or services of any such third party, including the
accuracy, completeness, or enforceability of any estate planning documents
Client Testimonials
A testimonial includes any statement by a current client about the client’s experience with TIM or its Supervised
Persons. Testimonials presented on TIM’s website or other marketing materials were provided by current clients
of the firm. Clients were not compensated, directly or indirectly, in exchange for their testimonials. Because
experiences are subjective and not all clients provide reviews, testimonials may not be representative of the
experience of all clients and are not a guarantee of future performance or success. TIM may request feedback
from clients and does not require that feedback be positive; however, TIM may choose whether to publish or
highlight particular testimonials. Where required, TIM will provide clear and prominent disclosures in connection
with the presentation of testimonials.
Item 15. Custody
TIM does not serve as a qualified custodian and encourages clients to maintain their assets with a qualified
custodian, typically Schwab or Fidelity. TIM is deemed to have custody in certain circumstances, including when it
has authority to deduct advisory fees directly from a client’s custodial account. In addition, some clients may
authorize TIM, through a standing letter of authorization ("SLOA") maintained with the custodian, to direct the
custodian to disburse funds to a specified third party. Separately, in limited cases involving employer-sponsored
retirement plan platforms, TIM may have client-authorized access credentials that permit trading or allocation
changes within the plan. Clients should understand the scope of any authorization granted to TIM and may revoke
or limit such authority at any time by written notice (and, where applicable, by updating authorizations with the
custodian or plan provider).
The custodians recommended by TIM send a statement to the client, at least quarterly, indicating all amounts
disbursed from the account including the amount of management fees paid directly to TIM. In addition, as
discussed in Item 13, TIM also sends quarterly performance reports to certain clients. Clients should carefully
review the statements sent directly by the Financial Institutions and compare them to those received from TIM.
We urge you to carefully review your custodian’s statements and compare such official custodial records to the
account statements that we provide to you. Our statements vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities. If you ever have a question about
an entry on your TIM report(s), please call us immediately.
Surprise Independent Examination
With respect to any arrangement in which TIM’s access to client assets could be deemed custody beyond fee
deduction and SLOAs that satisfy applicable SEC conditions, TIM will comply with the custody rule requirements
applicable to the specific facts and circumstances, which may include engaging an independent public accountant
to conduct a surprise examination. Clients will receive account statements directly from their qualified custodian
or retirement plan provider and should review those statements promptly. TIM does not accept physical
possession of client funds or securities and does not move client assets except as authorized in writing by the
client and implemented by the qualified custodian or plan provider.
Item 16. Investment Discretion
TIM is normally given the authority to exercise investment discretion on behalf of clients. TIM is considered
to exercise investment discretion over a client’s account if it can effect transactions for the client without first
having to seek the client’s consent. TIM is given this authority through a limited power-of-attorney included in
the agreement between TIM and the client. Clients may request a limitation on this authority (such as certain
securities not to be bought or sold). TIM takes discretion over the following activities:
• The securities to be purchased or sold;
• The amount of securities to be purchased or sold; and
• When transactions are made.
Item 17. Voting Client Securities
TIM is required to disclose if it accepts authority to vote client securities. TIM does not generally vote client
securities on behalf of its clients and will do so only if agreed to in writing. Clients receive proxies directly from
the Financial Institutions and may contact the firm with any questions by calling the number on the cover of this
brochure.
Item 18. Financial Information
TIM does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance. In
addition, TIM is required to disclose any financial condition that is reasonably likely to impair its ability to meet
contractual commitments to clients. At this time, we reasonably believe that our firm is able to meet all of our
contractual commitments.