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ITEM 1 – COVER PAGE
TRIFECTA CAPITAL ADVISORS, LLC.
MARCH 13, 2025
Trifecta Capital Advisors, LLC
400 Skokie Blvd., Suite 455
Northbrook, IL 60062
Phone: 1-847-495-2464
www.trifectacapitaladvisors.com
This brochure provides information about the qualifications and business practices of Trifecta Capital Advisors,
LLC (“Trifecta”). If you have any questions about the contents of this brochure, please contact us at 1-847-495-
2464. The information in this brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority. Trifecta is a Registered Investment Adviser.
Registration as an Investment Adviser with the United States Securities and Exchange Commission or any state
securities authority does not imply a certain level of skill or training.
information about Trifecta Capital Advisors, LLC
is available on the SEC’s website at
Additional
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as an IARD number.
The IARD number for Trifecta is IARD# 317391
ITEM 2 – MATERIAL CHANGES
SUMMARY OF MATERIAL CHANGES
This section of the Brochure will address only those “material changes” that have been incorporated since our
last delivery or posting of this document on the SEC’s public disclosure website (IAPD) www.adviserinfo.sec.gov.
Since our last Annual Amendment filing on February 6, 2024, the following material changes were made:
•
Item 18 was updated to reflect the firm no longer has a Schwab Advisor Business Loan.
A free copy of our Brochure may be requested by contacting Sue Oleari, Chief Compliance Officer of Trifecta at
1-847-495-2464.
The Brochure is also available on our website at www.trifectacapitaladvisors.com.
We encourage you to read this document in its entirety.
ITEM 3 – TABLE OF CONTENTS
ITEM 1 – COVER PAGE
1
ITEM 2 – MATERIAL CHANGES
2
ITEM 3 – TABLE OF CONTENTS
3
ITEM 4 – ADVISORY BUSINESS
4
ITEM 5 – FEES AND COMPENSATION
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
13
ITEM 12 - BROKERAGE PRACTICES
14
ITEM 13 - REVIEW OF ACCOUNTS
16
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
16
ITEM 15 – CUSTODY
17
ITEM 16 – INVESTMENT DISCRETION
18
ITEM 17 – VOTING CLIENT SECURITIES
18
ITEM 18 – FINANCIAL INFORMATION
19
2B BROCHURE – JEFFREY “JEFF” BRENT BERMAN
20
2B BROCHURE – SUE OLEARI, CDFA®
22
2B BROCHURE – PAUL A. TROMP, CFP®
25
ITEM 4 – ADVISORY BUSINESS
This Disclosure document is being offered to you by Trifecta Capital Advisors, LLC (“Trifecta” or “Firm”) about
the investment advisory services we provide. It discloses information about our services and the way those
services are made available to you, the client.
Our Firm became a registered investment adviser in January 2022 and is owned by Paul Tromp, Sue Oleari, and
Jeff Berman, one-third each. Sue Oleari is the Chief Compliance Officer.
We are committed to helping clients build, manage, and preserve their wealth. Our Firm provides services that
help clients to achieve their stated financial goals. We will offer an initial complimentary meeting upon our
discretion; however, investment advisory services are initiated only after you and Trifecta execute an Investment
Management Agreement.
INVESTMENT AND WEALTH MANAGEMENT AND SUPERVISION SERVICES
We manage advisory accounts on a discretionary basis. For discretionary accounts, once we have determined
a profile and investment plan with a client, we will execute the day-to-day transactions without seeking prior
client consent but within the expected investment guidelines. We may accept accounts with certain restrictions
if circumstances warrant. We primarily allocate client assets among cash, individual stocks, bonds, exchange-
traded funds (“ETFs”), options, mutual funds, and other public and private securities or investments. We
generally invest Client’s cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade
commercial paper, and/or government-backed debt instruments. Ultimately, we try to achieve the highest
return on our client’s cash balances through relatively low-risk and conservative investments. In most cases, at
least a partial cash balance will be maintained in a money market account so that our firm may debit advisory
fees for our services.
During personal discussions with clients, we determine the client’s objectives, time horizons, risk tolerance, and
liquidity needs. As appropriate, we also review a client’s prior investment history, as well as family composition
and background. We develop a client’s personal and investment plan based on client needs. Portfolios will be
designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once
the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if
necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. We then create and
manage the client’s investments based on that policy and plan. It is the client’s obligation to notify us
immediately if circumstances have changed with respect to their goals.
With our discretionary relationship, we will make changes to the portfolio, as we deem appropriate, to meet
client financial objectives. We trade these portfolios based on the combination of our market views and client
objectives, using our investment process. We tailor our advisory services to meet the needs of our clients and
seek to ensure that your portfolio is managed in a manner consistent with those needs and objectives. Clients
have the ability to leave standing instructions with us to refrain from investing in particular industries or invest
in limited amounts of securities.
In all cases, clients have a direct and beneficial interest in their securities, rather than an undivided interest in a
pool of securities. We do have limited authority to direct the Custodian to deduct our investment advisory fees
from your accounts, but only with the appropriate written authorization from clients.
Where appropriate, we provide advice about any type of legacy position held in client portfolios. Typically, these
are assets that are ineligible to be custodied at our primary custodian. Clients may request us to advise on certain
investment products that are not maintained at their primary custodian, such as variable life insurance, annuity
contracts, and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans).
You are advised and expected to understand that our past performance does not guarantee future results.
Certain market and economic risks exist that adversely affect an account’s performance. This could result in
capital losses in your account.
EMONEY ADVISOR PLATFORM
Our Firm makes available to Clients the “eMoney Advisor” platforms to provide periodic comprehensive
reporting services that can incorporate all the Client’s investment assets, including those investment
assets that are not part of the assets managed by our Firm (“Excluded Assets”). The Client and their
other advisors that maintain trading authority, and not our Firm, shall be exclusively responsible for the
investment performance of the excluded assets.
Unless otherwise expressly agreed to in writing, our Firm’s service relative to the excluded assets is
limited to reporting only. Therefore, we shall not be responsible for the investment performance of the
excluded assets. Instead, the Client and the Client's designated outside investment professional(s)
maintain supervision, monitoring, and trading authority for the excluded assets. If our Client prefers,
we make recommendations as to any excluded assets, the Client has no obligation to accept the rec-
ommendation, and we shall not be responsible for any implementation error (timing, trading, etc.) rel-
ative to the excluded assets. If the Client prefers, we provide investment advisory services for the ex-
cluded assets, the Client may engage us under the terms and conditions of a Consulting or Investment
Advisory Agreement between our Firm and the Client.
eMoney Advisor Platform may also provide access to other types of information, including financial
planning concepts, which should not be construed as our Firm’s personalized investment advice or rec-
ommendations. We shall not be held responsible for any adverse results a Client may experience if the
Client engages in financial planning or other functions available on the eMoney Advisor Platform with-
out our assistance or oversight.
THIRD-PARTY MONEY MANAGER (“TPMM”) SERVICES
Occasionally our firm utilizes a third-party's sub-advisory services to manage client accounts and offer funds to
clients managed to a specific investment objective. The client will not engage the subadvisor directly; the
client’s advisory relationship remains with Trifecta as set forth in the client’s Investment Advisory Agreement.
Our firm will not offer advice on any specific securities or other investments in connection with this service.
Prior to utilizing sub-advisors for our clients, our firm will provide initial due diligence on TPMM and ongoing
reviews of their management of client accounts. In order to assist in the selection of a sub-advisor, our firm will
gather client information pertaining to the financial situation, investment objectives, and reasonable
restrictions to be imposed upon the management of the account.
Our firm will periodically review third-party management reports provided to the client at least annually. Our
firm will contact clients from time to time in order to review their financial situation and objectives,
communicate information to TPMM as warranted, and assist the client in understanding and evaluating the
services provided by the sub-advisor. Clients will be expected to notify our firm of any changes in their financial
situation, investment objectives, or account restrictions that could affect their financial standing.
Our firm takes actions on behalf of the client to hire or fire money managers used in the implementation of a
client's investment plan and execution of the Advisory Agreement with our Firm. Therefore, the firm has the
discretionary authority to hire or fire the manager or to allocate assets among managers without obtaining the
Client’s consent.
FINANCIAL PLANNING
Through the financial planning process, our team strives to engage our clients in conversations around the
client’s goals, objectives, priorities, vision, and legacy – both for the near term as well as for future generations.
With the unique goals and circumstances of each client in mind, our team will offer financial planning ideas and
strategies to address the client’s holistic financial picture, including estate, income tax, charitable, cash flow,
wealth transfer, and client legacy objectives. Our team partners with our client’s other advisors (CPAs, Enrolled
Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure a coordinated effort of all parties toward the client’s
stated goals. Such services include various reports on specific goals and objectives or general investment and/or
planning recommendations, guidance to outside assets, and periodic updates.
Our specific services in preparing your plan may include:
§ Review and clarification of your financial goals
§ Assessment of your overall financial position including cash flow, balance sheet, investment strategy,
risk management, and estate planning
§ Creation of a unique plan for each goal you have, including personal and business real estate, education,
retirement or financial independence, charitable giving, estate planning, business succession, and other
personal goals
§ Development of a goal-oriented investment plan, with input from various advisors to our clients around
tax suggestions, asset allocation, expenses, risk, and liquidity factors for each goal. This includes IRA
and qualified plans, taxable, and trust accounts that require special attention
§ Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and transfer,
including liquidity as well as various insurance and possible company benefits; and
§ Crafting and implementation of, in conjunction with your estate and/or corporate attorneys as tax
adviser, an estate plan to provide for you and/or your heirs in the event of an incapacity or death
A written evaluation of each client's initial situation or Financial Plan is provided to the client. An annual review
will be provided by the Adviser, if indicated by the Client and Adviser per the Agreement. More frequent reviews
occur but are not necessarily communicated to the client unless immediate changes are recommended.
WRAP FEE PROGRAMS
Our Firm does not sponsor a Wrap Fee Program.
ASSETS
As of December 31, 2024, we had $712,181,349 in discretionary assets under management. We do not manage
any non-discretionary assets.
ITEM 5 – FEES AND COMPENSATION
INVESTMENT MANAGEMENT FEES AND COMPENSATION
Our Firm charges a fee as compensation for providing Investment Management services on your account. These
services include advisory services, trade entry, investment supervision, and other account maintenance
activities. Our recommended Custodian may charge transaction costs, custodial fees, redemption fees,
retirement plan and administrative fees or commissions. See Additional Fees and Expenses below for details.
A calendar monthly investment management fee is billed in arrears based on the average daily balance of your
account during the previous calendar month. Our maximum annual advisory fee is 1.25%. The relevant fee and
billing method are defined and agreed to by the firm and the client in the executed Investment Advisory
Agreement. This fee may be debited directly from your investment account or you may pay this fee separately.
You will need to indicate how you would like to pay this fee in your Investment Advisory Agreement. Additional
fees and expenses you may incur are brokerage commissions, principal markups and discounts, SEC fees, mutual
fund/ETF expense ratios, mutual fund 12B-1 fees, tax withholding on certain foreign securities, postage fees,
wire fees, bank charges, and other administration fees as authorized by you. Please refer to Section 12 for
information on brokerage fees and services.
Fees may vary based on the size of the account, complexity of the portfolio, extent of activity in the account, or
other reasons agreed upon by our Firm and you as the client. In certain circumstances, our fees and the timing
of the fee payments may be negotiated. Our employees and their family related accounts are charged a reduced
fee for our services.
Unless otherwise instructed by the Client, we will aggregate related client accounts for the purposes of
determining the account size and annualized fee. The common practice is often referred to as “house-holding”
portfolios for fee purposes and may result in lower fees than if fees were calculated on portfolios separately.
Our method of house-holding accounts for fee purposes looks at the overall family dynamic and relationship.
When applicable, and noted in Exhibit A of the Investment Management Agreement, legacy positions will also
be excluded from the fee calculation.
The independent and qualified custodian holding your funds and securities will debit your account directly for
the advisory fee and pay that fee to us. When establishing a relationship with Trifecta, you provide written
authorization permitting the fees to be paid directly from your account held by the qualified custodian. Further,
the qualified Custodian agrees to deliver an account statement to you on a monthly basis indicating all the
amounts deducted from the account including our advisory fees.
Either Trifecta or you may terminate the management agreement immediately upon written notice to the other
party. The management fee will be pro-rated to the date of termination, for the month in which the cancellation
notice was given and any earned fee will be billed to you by our Firm.
Upon termination, you are responsible for monitoring the securities in your account, and we will have no further
obligation to act or advise with respect to those assets. In the event of client’s death or disability, Trifecta will
continue management of the account until we are notified of client’s death or disability and given alternative
instructions by an authorized party.
In no case are Trifecta fees based on, or related to, the performance of your funds or investments.
THIRD-PARTY MONEY MANAGER (“TPMM”) FEES AND SERVICES
As discussed in Item 4 above, there are occasions where an independent TPMM acts as a sub-adviser to our
firm. In those circumstances, the sub-advisor manages the assets based on the parameters provided by our
firm. Under such arrangements where our firm elects to utilize a sub-advisor, depending on the sub-advisor
contract with Trifecta, the total advisory fee may be collected from the custodian by our firm or the sub-advisor.
This total fee includes our firm’s portion of the investment advisory fee as well as the sub-advisory fee. Total
fees are not to exceed 1.25%.
Trifecta may terminate the relationship with a sub-advisor that manages your assets at any time. Trifecta will
notify you of instances where we have terminated a relationship with any third-party manager you are investing
with. Trifecta will not conduct ongoing supervisory reviews of the sub-advisor following such termination.
Factors involved in the termination of a sub-advisor may include a failure to adhere to their stated management
style or your objectives, a material change in the professional staff of the third-party manager, unexplained
poor performance, unexplained inconsistency of account performance, or our decision to no longer include the
third-party manager on our list of approved TPMMs.
Trifecta offers several investment management programs. Account custodial services may be provided by
several account custodians depending on the investment management program offered. Programs may have
higher or lower fees than other programs available through Trifecta or available elsewhere. Investment
management programs may differ in the services provided and method or type of management offered, and
each may have different account minimums. Client reports will depend upon the management program
selected. Please see complete details in the program brochure and custodial account agreement for each
program recommended and offered.
FINANCIAL PLANNING FEES
For our Investment Management clients, financial planning services are included in the Investment
Management fees described above.
For stand-alone financial planning arrangements, we will negotiate the planning fees with you using a fixed fee.
Fees may vary based on the extent and complexity of your individual or family circumstances and the amount
of your assets under our management. Trifecta will determine your fee for the designated financial advisory
services based on a fixed fee arrangement described below.
Under our fixed fee arrangement, any fee will be agreed in advance of services being performed. The fee will
be determined based on factors including the complexity of your financial situation, agreed upon deliverables,
and whether or not you intend to implement any recommendations through Trifecta. Fixed fees for financial
plans will not exceed $20,000 for the initial plan and will include on-going review.
Typically, we complete a plan within a month and will present it to you within 60 days of the contract date, if
you have provided us all information needed to prepare the financial plan. One hundred (100%) of the Financial
Planning Fee is collected upon delivery of the Plan to you. You may terminate the financial planning agreement
by providing us with written notice. There is no penalty for termination of your financial planning agreement
prior to the plan being delivered to you. We will not require prepayment of more than $1,200 in fees per client,
six (6) or more months in advance of providing any services.
ADMINISTRATIVE SERVICES
We have contracted with an unaffiliated firm, Tamarac Reporting Services, “Tamarac”, to utilize their
technology platform which supports data reconciliation, performance reporting, fee calculation, client
relationship maintenance, at least quarterly performance evaluations, and other functions related to the
administrative tasks of managing client accounts. Due to this arrangement, Tamarac will have access to client
accounts, but Tamarac will not serve as an investment adviser to our clients. Trifecta and Tamarac are non-
affiliated companies. Tamarac charges our Firm an annual fee for each account administered by its software.
Please note that the fee charged to the client will not increase due to the annual fee Trifecta pays to Tamarac.
The annual fee is paid from the portion of the management fee retained by Trifecta.
ADDITIONAL FEES AND EXPENSES:
In addition to the advisory fees paid to our Firm, you 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 include custodial fees, charges imposed 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. Our brokerage practices are
described at length in Item 12, below.
When selecting investments for our clients’ portfolios we might choose mutual funds on your account
custodian’s Non-Transaction Fee (NTF) list. This means that your account custodian will not charge a transaction
fee or commission associated with the purchase or sale of the mutual fund.
The mutual fund companies that choose to participate in your custodian’s NTF fund program pay a fee to be
included in the NTF program. The fee that a mutual fund company pays to participate in the program is
ultimately borne by the owners of the mutual fund including clients of our Firm. When we decide whether to
choose a fund from your custodian’s NTF list or not, we consider our expected holding period of the fund, the
position size and the expense ratio of the fund versus alternative funds. Depending on our analysis and future
events, NTF funds might not always be in your best interest.
ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT
We do not charge advisory fees on a share of the capital appreciation of the funds or securities in a client
account (so-called performance-based fees), nor engage in side by side management.
ITEM 7 - TYPES OF CLIENTS
We offer investment advisory and financial planning services as described above to individuals, high net-worth
individuals, families, business owners, executives, foundations, trusts, non-profit and non-exempt entities,
corporations, and other business entities. Trifecta has a minimum $1,000,000 household balance to establish
an account with our Firm but this minimum is negotiable.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Trifecta offers ongoing portfolio management services based on the individual goals, objectives, time horizon,
and risk tolerance of each client. We oversee a consultative process which evaluates the client’s unique needs
and preferences and matches those with a strategically and/or tactically managed investment portfolio. Our
investment management process includes the due diligence and oversight with targeted strategies to meet
varying risk and return expectations. We believe that successful investment management is a combination of
skilled analytics and targeted portfolio guidelines organized around specific outcomes tied to the client’s
financial goals and objectives. Risk tolerance is often specific to account type or goal while also being
generalized across the financial portfolio.
While Trifecta strongly believes in the power of asset allocation and diversification, we also believe that a
tactical approach to balancing those diversified asset classes is preferred when possible. When tax efficiency
priorities of the client preclude trading activity, those preferences may be prioritized. Trifecta generally limits
its investment advice and/or money management to mutual funds, stocks, bonds, fixed income, and REITs.
Trifecta may use other securities to help diversify a portfolio when applicable.
PLANNING & ASSET ALLOCATION
Determine client’s appropriate asset allocation based on financial and non-financial goals, family, cash flow,
liquidity, expenses, risk tolerance, and time horizon. We then stress test these inputs to maximize the level of
return for any given risk level. Each client will have an investment policy statement with target allocations
related to stocks, bonds, cash, and commodities. Ranges (above and below target) will be built in around all
asset classes to allow for market fluctuation, the ability to increase/decrease based on market and economic
conditions, and to manage risk.
MACRO ASSET ALLOCATION
We use proprietary capital market assumptions for risk and return of each major asset class (stocks/bonds/cash)
as well as correlation data to provide a diversified investment portfolio across different sub asset classes. This
is the basis for our long-term strategic recommendations. Based on current global conditions and expectations
for the near term, we look at valuations, technical analysis and economic data, such as interest rates, inflation,
employment data, and other relevant factors to make tactical adjustments to our long-term recommendations.
Within stock and bond asset classes, we then allocate funds to sub asset classes based on similar criteria related
to valuation (absolute and relative), trends, and micro data. We will focus the major asset classes on domestic
large capitalization stocks and domestic investment-grade bonds. In addition, we may use other attractive asset
classes such as domestic small or medium size companies, international companies, commodities, or REITs for
diversification purposes. Similar diversification will be used within bonds by potentially incorporating high-yield
bonds or preferred stocks.
INDIVIDUAL SECURITIES/SECURITY SELECTION
We will invest in companies for long-term capital appreciation that are high-quality corporations with
management that concentrate on creating shareholder value. Our focus is on long-term growth and attractive
valuation. We will perform ongoing fundamental, bottom-up research using internal and external sources.
Companies we invest in will most likely have the following characteristics:
§ Compete in areas with large future market opportunities with positive secular trends
§ Have a competitive advantage or are in an industry with significant barriers to entry
§ Strong cash flows and balance sheets.
Bonds will be chosen based on specific tax situations, maturity, and quality. Each individual purchaser’s tax
situation will be analyzed to determine if tax-exempt or taxable bonds are appropriate. Maturity decisions will
focus on current and future yield curve analysis, domestic growth forecasts, and inflation expectations. We will
be diversified across different states and/or corporations to mitigate risk.
Mutual funds or exchange-traded funds will be used where appropriate using proprietary analytical research
and tools to determine best in class solutions. We may use active or passive mutual funds depending on the
situation or asset class. Where consistent alpha is demonstrated, active funds will be used.
METHODS OF ANALYSIS
Trifecta's methods of analysis include charting analysis, fundamental analysis, technical analysis, and cyclical
analysis.
§ CHARTING ANALYSIS: involves the use of patterns in performance charts. Trifecta uses this technique
to search for patterns used to help predict favorable conditions for buying and/or selling a security.
§ FUNDAMENTAL ANALYSIS: involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. Trifecta uses this primarily
in stock or bond only portfolios where insight into individual company behaviors is informative.
§ TECHNICAL ANALYSIS: involves the analysis of past market data; primarily price and volume. Technical
analysis can be done at the signal provider level where they are making ETF recommendations based
on their data analytics models.
§ CYCLICAL ANALYSIS involved the analysis of business cycles to find favorable conditions for buying
and/or selling a security. Because of the uncertainty of economic modeling, cyclical analysis is not used
to forecast future economic conditions.
There is no guarantee that a particular strategy will meet its investment goals. The investment strategies we
use will vary over time depending on various factors. Our Firm may give advice and take action for clients which
differs from advice given or the timing or nature of action taken for other clients with different objectives. Our
Firm is not obligated to initiate transactions for clients in any security which its principals, affiliates or employees
may purchase or sell for their own accounts or for other clients.
Clients should be aware that products have unique characteristics and their cost structures differ, sometimes
significantly.
USE OF ALTERNATIVE INVESTMENTS
If deemed appropriate for your portfolio, our Firm may recommend investments classified as "alternative
investments”. Alternative investments may include a broad range of underlying assets including, but not limited
to, hedge funds, private equity, venture capital, and registered, publicly traded securities. Alternative
investments are speculative, not suitable for all clients and intended for only experienced and sophisticated
investors who are willing to bear the high risk of the investment, which can include: loss of all or a substantial
portion of the investment due to leveraging, short-selling, or other speculative investment practices; lack of
liquidity in that there may be no secondary market for the fund and none expected to develop; volatility of
returns; potential for restrictions on transferring interest in the fund; potential lack of diversification and
resulting higher risk due to concentration of trading authority with a single adviser; absence of information
regarding valuations and pricing; potential for delays in tax reporting; less regulation and typically higher fees
than other investment options such as mutual funds. The SEC requires investors be accredited to invest in these
more speculative alternative investments. Investing in a fund that concentrates its investments in a few holdings
may involve heightened risk and result in greater price volatility.
RISK OF LOSS
A client’s investment portfolio is affected by general economic and market conditions, such as interest rates,
availability of credit, inflation rates, economic conditions, changes in laws and national and international
political circumstances.
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. Trifecta will assist Clients in determining an appropriate
strategy based on their tolerance for risk.
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). Trifecta 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 Trifecta of any changes in financial condition, goals
or other factors that may affect this analysis.
Our methods rely on the assumption that the underlying companies within our security allocations are
accurately reviewed by the rating agencies and other publicly-available sources of information about these
securities, are providing accurate and unbiased data. While we are alert to indications that data may be
incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information.
Investors should be aware that accounts are subject to the following risks:
§ ALTERNATIVE RISK - Alternative investments include other additional risks. Lock-up periods and other
terms obligate Clients to commit their capital investment for a minimum period, typically no less than
one or two years and sometimes up to 10 or more years. Illiquidity is considered a substantial risk and
will restrict the ability of a Client to liquidate an investment early, regardless of the success of the
investment. Alternative investments are difficult to value within a Client’s total portfolio. There may be
limited availability of suitable benchmarks for performance comparison; historical performance data
may also be limited.
In some cases, there may be a lack of transparency and regulation, providing an additional layer of risk.
Some alternative investments may involve the use of leverage and other speculative techniques. As a
result, some alternative investments may carry substantial additional risks, resulting in the loss of some
or all of the investment. Using leverage and certain other strategies will result in adverse tax
consequences for tax-exempt investors, such as the possibility of unrelated business taxable income, as
defined under the U.S. Internal Revenue Code.
§ CAPITALIZATION RISK - Small-cap and mid-cap companies may be hindered as a result of limited
resources or less diverse products or services Their stocks have historically been more volatile than the
stocks of larger, more established companies.
§ COMMODITIES RISK - If the commodity is purchased in physical form, such as gold bars and coins,
for example, there are risks associated with transporting it from the place of purchase and of storing it
securely over time. There are also risks that the transaction costs of buying or selling the
physical commodity may be high. Additionally, there may be liquidity risks (one-half of a gold coin
cannot be sold, for example). If the commodity is purchased in non-physical form, such as unallocated
gold accounts, ETFs or other unit and investment trusts, there are risks associated with the movement
in gold prices and the ability of the fund or trust manager to respond or deal with those price
movements. There also may be initial charges as well as annual management fees associated with the
fund or trust.
§ CREDIT RISK - Credit risk is the risk that the issuer of a security may be unable to make interest
payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived
change in an issuer’s financial strength may affect a security’s value and thus, impact the fund’s
performance.
§ CYBERSECURITY RISK - increased internet use makes a portfolio susceptible to operational and
informational security risks. In general, cyber incidents can result from deliberate attacks or
unintentional events. Cyberattacks include but are not limited to infection by computer viruses or other
malicious software code, gaining unauthorized access to systems, networks, or devices through
“hacking” or other means to misappropriate assets or sensitive information, corrupting data, or causing
operational disruption. Cybersecurity failures or breaches of third-party service providers may cause
disruptions at third-party service providers and impact our business operations, potentially resulting in
financial losses; the inability to transact business; violations of applicable privacy and other laws,
regulatory fines, or penalties; reputational damage; unanticipated expenses or other compensation
costs; or additional compliance costs. Our firm has an established business continuity and disaster
recovery plan and related cybersecurity procedures designed to prevent or reduce the impact of such
risks; there are inherent limitations in such plans and systems due in part to the evolving nature of
technology and cyberattack tactics.
losses from trading
in the secondary markets, and disruption
§ EXCHANGE-TRADED FUNDS - ETFs face market-trading risks, including the potential lack of an active
market for shares,
in the
creation/redemption process of the ETF. Any of these factors may lead to the fund’s shares trading at
either a premium or a discount to its “net asset value.”
§ FOREIGN SECURITIES AND CURRENCY RISK - Investments in international and emerging-market
securities include exposure to risks such as currency fluctuations, foreign taxes and regulations, and the
potential for illiquid markets and political instability.
§
INTEREST RATE RISK - In a rising rate environment, the value of fixed-income securities generally
declines, and the value of equity securities may be adversely affected.
§ MARKET RISK - Even a long-term investment approach cannot guarantee a profit. Economic, political,
and issuer-specific events will cause the value of securities to rise or fall. Because the value of
investment portfolios will fluctuate, there is the risk that you will lose money and your investment may
be worth more or less upon liquidation.
§ PERFORMANCE OF UNDERLYING MANAGERS - We select the mutual funds and ETFs in the asset
allocation portfolios. However, we depend on the manager of such funds to select individual
investments in accordance with their stated investment strategy.
§ SECURITIES LENDING RISK - Securities lending involves the risk that the fund loses money because
the borrower fails to return the securities in a timely manner or at all. The fund could also lose money
if the value of the collateral provided for loaned securities, or the value of the investments made with
the cash collateral, falls. These events could also trigger adverse tax consequences for the fund.
ITEM 9 - DISCIPLINARY INFORMATION
We do not have any legal, financial or other “disciplinary” item to report.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
OTHER FINANCIAL AFFILIATIONS
Neither our firm nor our associated persons engage in any other financial industry activities or have any other
financial industry affiliations.
ITEM 11 - CODE OF ETHICS
Our Firm and persons associated with us are allowed to invest for their own accounts, or to have a financial
investment in the same securities or other investments that we recommend or acquire for your account, and
may engage in transactions that are the same as or different than transactions recommended to or made for
your account. This creates a conflict of interest. We recognize the fiduciary responsibility to act in your best
interest and have established polices to mitigate conflicts of interest.
We have developed and implemented a Code of Ethics that sets forth standards of conduct expected of our
advisory personnel to mitigate this conflict of interest. The Code of Ethics addresses, among other things,
personal trading, gifts, and the prohibition against the use of inside information.
The Code of Ethics is designed to protect our clients to detect and deter misconduct, educate personnel
regarding the Firm’s expectations and laws governing their conduct, remind personnel that they are in a position
of trust and must act with complete propriety at all times, protect the reputation of Trifecta, safeguard against
the violation of the securities laws, and establish procedures for personnel to follow so that we may determine
whether their personnel are complying with the Firm’s ethical principles.
We have established the following restrictions in order to ensure our Firm’s fiduciary responsibilities:
§ A director, officer, or employee of Trifecta shall not buy or sell any securities for their personal
portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her
employment unless the information is also available to the investing public on reasonable inquiry.
§ No supervised employee of Trifecta shall prefer his or her own interest to that of the advisory client.
Trades for supervised employees are traded alongside client accounts.
§ We maintain a list of all securities holdings of anyone associated with this advisory practice with access
to advisory recommendations. These holdings are reviewed on a regular basis by an appropriate
officer/individual of Trifecta.
§ We emphasize the unrestricted right of the client to decline implementation of any advice rendered,
except in situations where we are granted discretionary authority of the client’s account.
§ We require that all supervised employees must act in accordance with all applicable Federal and State
regulations governing registered investment advisory practices.
§ Any supervised employee not in observance of the above may be subject to termination.
None of our associated persons may affect for himself/herself or for accounts in which he/she holds a beneficial
interest, any transactions in a security which is being actively recommended to any of our clients, unless in
accordance with the Firm’s procedures.
You may request a complete copy of our Code by contacting us at the address, telephone, or email on the cover
page of this Part 2; ATTN: Sue Oleari, Chief Compliance Officer.
ITEM 12 - BROKERAGE PRACTICES
We generally recommend that clients utilize the custody and brokerage services of Charles Schwab & Co., Inc.
Advisor Services (the “Custodians”) for investment management accounts. Our Custodians are independent and
unaffiliated FINRA-registered broker-dealers. We may recommend that you establish accounts with these
custodians to maintain custody of your assets and to effect trades for your accounts. Some of the products,
services and other benefits provided by our Custodians benefit us and may not benefit you or your account.
Our recommendation/requirement that you place assets with one of these custodians may be based in part on
benefits they provide us, and not solely on the nature, cost or quality of custody and execution services provided
by the Custodian.
We are independently owned and operated and not affiliated with these custodians. They provide us with
access to their institutional trading and custody services. These services include brokerage, custody, research
and access to mutual funds and other investments that are otherwise generally available only to institutional
investors.
In the event you request us to recommend a broker/dealer Custodian for execution and/or custodial services,
we generally recommend your account to be maintained at one of these Custodians. We may recommend that
you establish accounts with the Custodians to maintain custody of your assets and to effect trades for your
accounts. You have the right to not act upon any recommendations, and if you elect to act upon any
recommendations, you have the right to not place the transactions through any broker/dealer we recommend.
Our recommendation is generally based on the broker’s cost and fees, skills, reputation, dependability and
compatibility with the client. You may be able to obtain lower commissions and fees from other brokers and
the value of products, research and services given to us is not a factor in determining the selection of
broker/dealer or the reasonableness of their commissions.
We place trades for your account subject to our duty to seek best execution and other fiduciary duties. You may
be able to obtain lower commissions and fees from other brokers and the value of products, research and
services given to us is not a factor in determining the selection of broker/dealer or the reasonableness of their
commissions. The Custodian's execution quality may be different than other broker-dealers.
For our client accounts maintained in custody with a Custodian, the Custodian generally does not charge
separately for custody but are compensated by account holders through 12b-1 fees and ticket charges.
The Custodians we utilize makes available to us other products and services that benefit us but may not benefit
your accounts in every case. Some of these other products and services assist us in managing and administering
your accounts. These include software and technology that provide access to client account data (such as trade
confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders
for multiple client accounts), provide research, pricing information and other market data, facilitate payment
of our fees from your account, and assist with back-office functions, record-keeping and reporting.
Many of these services generally may be used to service all or a substantial number of our accounts. The
Custodians also make available to us other services intended to help us manage and further develop its business
enterprise. These services may include consulting, publications and conferences on practice management,
information technology, business succession, regulatory compliance, and marketing. In addition, the
Custodians may make available, arrange and/or pay for these services rendered to us by third parties. The
Custodians may discount or waive fees it would otherwise charge for some of these services or pay all or a part
of the fees of a third-party providing these services to us.
While as a fiduciary, we endeavor to act in your best interest, our recommendation that you maintain your
assets in accounts at our recommended Custodians may be based in part on the benefit to us or the availability
of some of the foregoing products and services and not solely on the nature, cost or quality of custody and
brokerage services provided by the Custodian, which may create a conflict of interest. IARs endeavor at all times
to put the interest of our clients first as a part of their fiduciary duty.
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific
broker or dealer in order to obtain goods or services on behalf of the plan. Such direction is permitted provided
that the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its
business for which it otherwise would be obligated and empowered to pay. ERISA prohibits directed brokerage
arrangements when the goods or services purchased are not for the exclusive benefit of the plan. Consequently,
we will request that plan sponsors who direct plan brokerage provide us with a letter documenting that this
arrangement will be for the exclusive benefit of the plan.
AGGREGATION AND ALLOCATION OF TRANSACTIONS
We may aggregate transactions if we believe that aggregation is consistent with the duty to seek best execution
for our clients and is consistent with the disclosures made to clients and terms defined in the client Investment
Advisory Agreement. No advisory client will be favored over any other client, and each account that participates
in an aggregated order will participate at the average share price (per custodian) for all transactions in that
security on a given business day. We will aggregate trades for ourselves or our associated persons with your
trades, providing that the following conditions are met:
§ Our policy for the aggregation of transactions shall be fully-disclosed separately to our existing clients
(if any) and the broker/dealer(s) through which such transactions will be placed;
§ We will not aggregate transactions unless we believe that aggregation is consistent with our duty to
seek the best execution (which includes the duty to seek best price) for you and is consistent with the
terms of our Investment Advisory Agreement with you for which trades are being aggregated;
§ No advisory client will be favored over any other client; each client that participates in an aggregated
order will participate at the average share price for all our transactions in a given security on a given
business day, with transaction costs based on each client’s participation in the transaction;
§ We will prepare a written statement (“Allocation Statement”) specifying the participating client
§
accounts and how to allocate the order among those clients;
If the aggregated order is filled in its entirety, it will be allocated among clients in accordance with the
allocation statement; if the order is partially filled, the accounts that did not receive the previous trade’s
positions should be “first in line” to receive the next allocation;
§ Notwithstanding the foregoing, the order may be allocated on a basis different from that specified in
the Allocation Statement if all client accounts receive fair and equitable treatment and the reason for
difference of allocation is explained in writing and is reviewed by our compliance officer. Our books
and records will separately reflect, for each client account, the orders of which aggregated, the
securities held by, and bought for that account;
§ We will receive no additional compensation or remuneration of any kind as a result of the proposed
§
aggregation; and,
Individual advice and treatment will be accorded to each advisory client.
BROKERAGE FOR CLIENT REFERRALS
Our Firm does not receive client referrals from any Custodian or third party in exchange for using that broker-
dealer or third party.
TRADE ERRORS
We have implemented procedures designed to prevent trade errors; however, trade errors in client accounts
cannot always be avoided. Consistent with our fiduciary duty, it is our policy to correct trade errors in a manner
that is in the best interest of the client. In cases where the client causes the trade error, the client will be
responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade
error, the client may not be able to receive any gains generated as a result of the error correction. In all
situations where the client does not cause the trade error, the client will be made whole and we will absorb any
loss resulting from the trade error if the error was caused by the firm. If the error is caused by the Custodian,
the Custodian will be responsible for covering all trade error costs. If an investment gain results from the
correcting trade, the gain will be donated to charity. We will never benefit or profit from trade errors.
DIRECTED BROKERAGE
We do not routinely recommend, request or require that you direct us to execute transaction through a
specified broker dealer. Additionally, we typically do not permit you to direct brokerage. We place trades for
your account subject to our duty to seek best execution and other fiduciary duties.
ITEM 13 - REVIEW OF ACCOUNTS
ACCOUNT REVIEWS AND REVIEWERS – INVESTMENT SUPERVISORY SERVICES
Our Investment Adviser Representatives will monitor client accounts on a regular basis and perform annual
reviews with each client. All accounts are reviewed for consistency with client investment strategy, asset
allocation, risk tolerance, and performance relative to the appropriate benchmark. More frequent reviews may
be triggered by changes in an account holder’s personal, tax, or financial status. Geopolitical and
macroeconomic specific events may also trigger reviews.
STATEMENTS AND REPORTS
The custodian for the individual client’s account will provide clients with an account statement at least monthly.
Upon request, clients can receive a prepared written report detailing their current positions, asset allocation,
and year-to-date performance provided by our Firm.
You are urged to compare the reports provided by Trifecta against the account statements you receive directly
from your account custodian.
• Financial Planning Services – Your review will be conducted by your assigned Investment Advisor. We
realize that events and circumstances could change dramatically in between normal reviews.
Therefore, if you experience an event in your life that might necessitate an early review of your Financial
Plan, please let us know and we will be happy to schedule a more frequent review. Such an event might
include a marriage, divorce, birth of a child, death or disability of an immediate family member,
impending retirement, employment status, or you bought or sold a business. We also encourage you
to ask us if you have any questions about your Financial Plan or the reports that we generate.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
Our Firm, and its related entities, do not directly or indirectly compensate any person who is not an IAR of our
firm nor receive any compensation for any client referrals.
As disclosed under Item 12 Brokerage Practices, we participate in the various Custodian’s institutional customer
programs and we may recommend a Custodian to you for custody and brokerage services. There is no direct
link between our participation in the program and the investment advice we give to our clients, although we
receive economic benefits through our participation in the program that are typically not available to any other
independent Investment Advisors participating in the program. These benefits include the following products
and services (provided without cost or at a discount): receipt of duplicate Client statements and confirmations;
research related products and tools; consulting services; access to a trading desk serving adviser participants;
access to block trading (which provides the ability to aggregate securities transactions for execution and then
allocate the appropriate shares to Client accounts); the ability to have advisory fees deducted directly from
Client accounts; access to an electronic communications network for Client order entry and account
information; access to mutual funds with no transaction fees and to certain institutional money managers; and
discounts on compliance, marketing, research, technology, and practice management products or services
provided to us by third party vendors. Custodians may also have paid for business consulting and professional
services received by some of our related persons. Some of the products and services made available by
Custodians through the program may benefit us but may not benefit your account. These products or services
may assist us in managing and administering your account, including accounts not maintained at Custodian.
Other services made available by Custodian are intended to help us manage and further develop our business
enterprise. The benefits our Firm or our personnel receive through participation in the program do not depend
on the amount of brokerage transactions directed to Custodian. As part of our fiduciary duties to clients, we
always endeavor to put our clients' interests first. You should be aware, however, that the receipt of economic
benefits by our Firm or our related persons in and of itself creates a conflict of interest and may indirectly
influence our choice of Custodian for custody and brokerage services.
ITEM 15 – CUSTODY
We do not have physical custody, as it applies to investment advisors. Custody has been defined by regulators
as having access or control over client funds and/or securities.
DEDUCTION OF ADVISORY FEES
For all accounts, our Firm has the authority to have fees deducted directly from client accounts. Our Firm has
established procedures to ensure all client funds and securities are held at a qualified custodian in a separate
account for each client under that client’s name. Clients, or an independent representative of the client, will
direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name,
address, and the way the funds or securities are maintained. Finally, account statements are delivered directly
from the qualified custodian to each client, or the client’s independent representative, at least quarterly. You
should carefully review those statements and are urged to compare the statements against reports received
from Trifecta. When you have questions about your account statements, you should contact Trifecta or the
qualified custodian preparing the statement.
Please refer to Item 5 for more information about the deduction of adviser fees.
STANDING LETTERS OF AUTHORIZATION (“SLOA”)
Our Firm is deemed to have custody of clients’ funds or securities when you have standing authorizations with
their custodian to move money from your account to a third-party (“SLOA”) and, under that SLOA, it authorizes
us to designate the amount or timing of transfers with the custodian. The SEC has set forth standards intended
to protect your assets in such situations, which we follow. We do not have a beneficial interest in any of the
accounts we are deemed to have Custody where SLOAs are on file. In addition, account statements reflecting
all activity on the account(s), are delivered directly from the qualified custodian to each client or the client’s
independent representative at least monthly. You should carefully review those statements and are urged to
compare the statements against reports received from us. When you have questions about your account
statements, you should contact us, your Adviser or the qualified custodian preparing the statement.
ITEM 16 – INVESTMENT DISCRETION
For discretionary accounts, prior to engaging Trifecta to provide investment advisory services, you will enter a
written Agreement with us granting the Firm the authority to supervise and direct, on an on-going basis,
investments in accordance with the client’s investment objective and guidelines. In addition, you will need to
execute additional documents required by the Custodian to authorize and enable Trifecta, in its sole discretion,
without prior consultation with or ratification by you, to purchase, sell, or exchange securities in and for your
accounts. We are authorized, in our discretion and without prior consultation with you to: (1) buy, sell, exchange
and trade any stocks, bonds or other securities or assets and (2) determine the amount of securities to be
bought or sold, and (3) place orders with the custodian. Any limitations to such discretionary authority will be
communicated to our Firm in writing by you, the client.
The limitations on investment and brokerage discretion held by Trifecta for you are:
§ For discretionary accounts, we require that we be provided with the authority to determine which
securities and the amounts of securities to be bought or sold.
§ Any limitations on this discretionary authority shall in writing as indicated on the investment advisory
Agreement, Appendix B. You may change/amend these limitations as required.
In some instances, we may not have discretion. We will discuss all transactions with you prior to execution or
you will be required to make the trades if in an employer-sponsored account.
ITEM 17 – VOTING CLIENT SECURITIES
PROXY VOTING
We will not vote proxies on your behalf. You are welcome to vote proxies or designate an independent third-
party at your own discretion. You designate proxy voting authority in the custodial account documents. You
must ensure that proxy materials are sent directly to you or your assigned third party. We do not act with
respect to any securities or other investments that become the subject of any legal proceedings, including
bankruptcies. Clients can contact our office with questions about a particular proxy solicitation by phone at
847-495-2464.
CORPORATE ACTIONS
We will accept the client's delegated authority to vote on Corporate Actions for securities held within certain
clients' portfolios. We have adopted policies and procedures reasonably designed to ensure that voting is in
clients' best interest in accounts where we exercise voting discretion.
In upholding our fiduciary obligation to you, we strive to keep our Corporate Action votes free from
inappropriate influences. We exercise voting responsibilities in a method that serves you as shareholders of a
company. When we have been granted the authority to vote on Corporate Actions by the client, unless directed
otherwise, we will vote on each Corporate Action at our discretion. We reserve the right to abstain on any
particular vote or otherwise withhold the vote on any matter if, in the judgment of Trifecta, the circumstances
make such an abstention or withholding otherwise advisable and in the best interests of our clients.
We keep detailed records of all client votes in accordance with the SEC recordkeeping rule.
CLASS ACTION
Trifecta personnel may answer client questions regarding Class Action matters in an effort to assist the client in
determining how to proceed with the Class Action. However, Trifecta does not take any action or render any
advice on materials relating to any class action lawsuit involving a security held in a client's account. Trifecta
will promptly forward any such class action lawsuit materials for direct action by the Client to the Client via
Certified Mail with a return receipt requested.
ITEM 18 – FINANCIAL INFORMATION
We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance.
Therefore, we are not required to include a balance sheet for our most recent fiscal year. We are not subject
to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients.
Finally, we have not been the subject of a bankruptcy petition at any time.
2B BROCHURE – JEFFREY “JEFF” BRENT BERMAN
ITEM 1 – COVER PAGE
TRIFECTA CAPITAL ADVISORS, LLC
400 SKOKIE BOULEVARD, SUITE 455
NORTHBROOK, IL 60062
847-495-2462
2B Brochure
Jeffrey “Jeff” Brent Berman
MARCH 2025
This brochure supplement provides information about Jeff Berman that supplements our brochure. You
should have received a copy of that brochure. Please contact Jeff Berman if you did not receive the Trifecta
Capital Advisors, LLC brochure or if you have any questions about the contents of this supplement.
Additional information about Jeff Berman is available on the SEC’s website at www.adviserinfo.sec.gov by
searching CRD#7480586.
ITEM 2 – EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
Jeffrey “Jeff” Brent Berman
Year of Birth: 1976
Educational Background:
Lake Forest Graduate School, MBA, 2006
• DePaul University, Bachelor’s Degree, Business, 1998
•
• NASAA Uniform Investment Adviser Law Exam, Series 65, 2021
Business Background:
• Trifecta Capital Advisors, LLC, Investment Adviser Representative, 01/2022- Present
• Harris Bank/BMO, Director, 10/2010-01/2022
•
LaSalle Bank/BofA, Director, 3/1999-10/2010
ITEM 3 – DISCIPLINARY INFORMATION
is a
resource available
to
the disciplinary history of
Jeff Berman has no history of any legal or disciplinary events that Trifecta Capital Advisors, LLC deems to be
material to a client’s consideration of Jeff Berman to act as their investment adviser representative. FINRA’s
BrokerCheck®
Jeff Berman.
review
https://brokercheck.finra.org/
ITEM 4 – OTHER BUSINESS ACTIVITIES
Jeff Berman does not have outside business activities to disclose.
ITEM 5 – ADDITIONAL COMPENSATION
Jeff Berman does not receive any other economic benefit for providing advisory services in addition to
advisory fees.
ITEM 6 – SUPERVISION
Jeff Berman is supervised through a compliance program designed to prevent and detect violations of the
federal and state securities laws. Supervision is conducted by the Chief Compliance Officer, Sue Oleari, who is
responsible for administering the policies and procedures. As Chief Compliance Officer, Sue Oleari reviews
those policies and procedures regularly and annually at a minimum for their adequacy and the effectiveness of
their implementation. All policies and procedures of the firm are followed. Sue Oleari may be reached at 847-
495-2464.
2B BROCHURE – SUE OLEARI, CDFA®
ITEM 1 – COVER PAGE
TRIFECTA CAPITAL ADVISORS, LLC
400 SKOKIE BOULEVARD, SUITE 455
NORTHBROOK, IL 60062
847-495-2464
2B Brochure
Susan “Sue” Gerstein Oleari, CDFA®
MARCH 2025
This brochure supplement provides information about Sue Oleari that supplements our brochure. You
should have received a copy of that brochure. Please contact Sue Oleari if you did not receive the Trifecta
Capital Advisors, LLC brochure or if you have any questions about the contents of this supplement.
Additional information about Sue Oleari is available on the SEC’s website at www.adviserinfo.sec.gov by
searching CRD# 6660230.
ITEM 2 – EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
Susan Gerstein Oleari, CDFA®
Year of Birth: 1970
Educational Background:
• University of Illinois, Bachelor’s Degree with honors, Finance, 1992
• CBA Executive Banking Graduate School, 2015
• NASAA Uniform Investment Adviser Law Exam, Series 65, 2021
Business Background:
• Trifecta Capital Advisors, LLC, Investment Adviser Representative/CCO, 01/2022 – Present
• Harris Bank/BMO, Commercial, Retail and Wealth Leader, 07/1992 – 01/2022
Professional Designations:
• Certified Divorce Financial Analyst (CDFA)*, 2022
* Certified Divorce Financial Analyst (CDFA®) Designation
A CDFA® is an expert in the unique financial circumstances that surround a divorce. The professional training for the certification is
focused on understanding and estimating the long-term costs of a divorce, because divorce settlements can impact a person's financial
picture for a very long time. Areas of expertise include:
•
Tax consequences of divorce agreements
•
The process of dividing and valuing property fairly
•
Determining how much alimony and/or child support is appropriate and for how long
• Modeling the future values of retirement and pension funds
ITEM 3 – DISCIPLINARY INFORMATION
is a
resource available
to
review
Sue Oleari has no history of any legal or disciplinary events that Trifecta Capital Advisors, LLC deems to be
material to a client’s consideration of Sue Oleari to act as their investment adviser representative. FINRA’s
BrokerCheck®
the disciplinary history of Sue Oleari.
https://brokercheck.finra.org/
ITEM 4 – OTHER BUSINESS ACTIVITIES
Sue Oleari serves on the Board of Directors for the Joffrey Ballet, Evan Joseph Gerstein Foundation and
Recipe for Change. She attends board and committee meetings but does not have check writing authority
for Joffrey Ballet and Evan Joseph Gerstein Foundation. Ms. Oleari does have check writing authority for
Recipe for Change. This does not create a conflict as Recipe for Change is not a client of the firm. Ms.
Oleari receives no compensation and spends less than 3 hours per month in her role.
ITEM 5 – ADDITIONAL COMPENSATION
Sue Oleari does not receive any other economic benefit for providing advisory services in addition to
advisory fees.
ITEM 6 – SUPERVISION
Sue Oleari is Chief Compliance Officer of Trifecta Capital Advisors, LLC. She supervises and oversees all activities
conducted through the firm and maintains policies and procedures to guide activities. Sue Oleari reviews those
policies and procedures regularly and annually at a minimum for their adequacy and the effectiveness of their
implementation. Sue Oleari may be reached at 847-495-2464.
2B BROCHURE – PAUL A. TROMP, CFP®
ITEM 1 – COVER PAGE
TRIFECTA CAPITAL ADVISORS, LLC
400 SKOKIE BOULEVARD, SUITE 455
NORTHBROOK, IL 60062
847-495-2464
2B Brochure
Paul A. Tromp, CFP®
MARCH 2025
This brochure supplement provides information about Paul Tromp that supplements our brochure. You
should have received a copy of that brochure. Please contact Paul Tromp if you did not receive the Trifecta
Capital Advisors, LLC brochure or if you have any questions about the contents of this supplement.
Additional information about Paul Tromp is available on the SEC’s website at www.adviserinfo.sec.gov by
searching CRD# 4980542.
ITEM 2 – EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
Paul A. Tromp, CFP®
Year of Birth: 1978
Educational Background:
• University of Illinois, Bachelor’s Degree, Accounting, 2000
Business Background:
• Trifecta Capital Advisors, LLC, Investment Adviser Representative, 03/2022- Present
• Harris Bank/BMO, Private Wealth Advisor, 07/2002 – 3/2022
Professional Designations:
•
1Certified Financial Planner™ (CFP®), 2005
§
§
§
§
1Minimum Qualifications for The CERTIFIED FINANCIAL PLANNER™ (CFP®) Designation.
The Certified Financial Planner™, CFP®, and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by
the Certified Financial Planner Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is voluntary; no federal or state law or regulation requires financial planners
to hold CFP® certification. It is recognized in the United States and several other countries for its (1)
high standard of professional education; (2) stringent code of conduct and standards of practice;
and (3) ethical requirements that govern professional engagements with clients.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following
requirements:
•
•
•
•
•
•
•
Education – Complete an advanced college-level course of study addressing the financial
planning subject areas that the CFP® Board’s studies have determined as necessary for the
competent and professional delivery of financial planning services and attain a bachelor’s
degree from a regionally accredited United States college or university (or its equivalent
from a foreign university). CFP® Board’s financial planning subject areas include insurance
planning and risk management, employee benefits planning, investment planning, income
tax planning, retirement planning, and estate planning;
Examination – Pass the comprehensive CFP® Certification Examination. The examination,
administered in 10 hours over two days, includes case studies and client scenarios designed
to test one’s ability to correctly diagnose financial planning issues and apply one’s
knowledge of financial planning to real-world circumstances;
Experience – Complete at least three years of full-time financial planning-related experience
(or the equivalent, measured as 2,000 hours per year); and
Ethics – Agree to be bound by the CFP® Board’s Standards of Professional Conduct, a set of
documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements to maintain the right to continue to use the CFP® marks:
Continuing Education – Complete 30 hours of continuing education hours every two (2)
years, including two (2) hours on the Code of Ethics and other parts of the Standards of
Professional Conduct, to maintain competence and keep up with developments in the finan-
cial planning field; and
Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The
Standards prominently require that CFP® professionals provide financial planning services at
a fiduciary standard of care. This means CFP® professionals must act in the best interest of
their clients at all times when providing financial advice.
§
CFP® professionals who fail to comply with the above standards and requirements may be subject
to the CFP® Board’s enforcement process, which could result in suspension or permanent revocation
of their CFP® certification.
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In addition, as a CFP® professional, I will adhere to the Standards of Conduct developed by the CFP®
Board. At all times, when providing Financial Advice to a Client, a CFP® professional must act as a
fiduciary and, therefore, act in the best interest of the Client. The Standards cover duties owed to
clients, the practice standards for the financial planning process, and duties owed to the Firm and
the regulators.
In complying with the Practice Standards, as a CFP® professional, I will act prudently in documenting
information, as the facts and circumstances require, considering the significance of the information,
the need to preserve the information in writing, the obligation to act in the Client’s best interest,
and the CFP® Professional’s Firm’s policies and procedures. The financial planning process will cover
the following:
• Understanding the Client’s Personal and Financial Circumstances
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Identifying and Selecting Goals
Analyzing the Client’s Current Course of Action and Potential Alternative Course(s) of Ac-
tion
Developing the Financial Planning Recommendation(s)
Presenting the Financial Planning Recommendation(s)
Implementing the Financial Planning Recommendation(s)
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• Monitoring Progress and Updating
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Trifecta Capital Advisors suggests a thorough review of the Standards by visiting:
https://www.cfp.net/ethics/code-of-ethics-and-standards-of-conduct.
ITEM 3 – DISCIPLINARY INFORMATION
Paul Tromp has no history of any legal or disciplinary events that Trifecta Capital Advisors, LLC
deems to be material to a client’s consideration of Paul Tromp to act as their investment
adviser representative. FINRA’s BrokerCheck® is a resource available to review the disciplinary
history of Paul Tromp. https://brokercheck.finra.org/
ITEM 4 – OTHER BUSINESS ACTIVITIES
Paul Tromp does not have outside business activities to disclose.
ITEM 5 – ADDITIONAL COMPENSATION
Paul Tromp does not receive any other economic benefit for providing advisory services in
addition to advisory fees.
ITEM 6 – SUPERVISION
Paul Tromp is supervised through a compliance program designed to prevent and detect
violations of the federal and state securities laws. Supervision is conducted by the Chief
Compliance Officer, Sue Oleari, who is responsible for administering the policies and procedures.
As Chief Compliance Officer, Sue Oleari reviews those policies and procedures annually for their
adequacy and the effectiveness of their implementation. All policies and procedures of the firm
are followed. Sue Oleari may be reached at 847-495-2464.