View Document Text
True Vision MN LLC dba True Vision Financial Advisors
Form ADV Part 2A – Disclosure Brochure
Effective: February 17, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices
of True Vision MN LLC (“True Vision” or the “Advisor”). If you have any questions about the content of this Disclosure
Brochure, please contact the Advisor at 612-256-2208 or by email at dpilacinski@truevisionadv.com.
True Vision is a registered investment advisor with the U.S. Securities and Exchange Commission. The information
in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission
(“SEC”) or by any state securities authority. Registration of an investment advisor does not imply any specific level
of skill or training. This Disclosure Brochure provides information about True Vision to assist you in determining
whether to retain the Advisor.
Additional information about True Vision and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 322783.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of True Vision. For convenience, the Advisor has combined these documents into a single disclosure
document.
True Vision believes that communication and transparency are the foundation of its relationship with clients and will
continually strive to provide you with complete and accurate information at all times. True Vision encourages all
current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the
Advisor.
Material Changes
There have been no material changes to this Disclosure Brochure since the last annual amendment filing February
14, 2025.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes
in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure
or a Summary of Material Changes shall be provided to you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 322783. You may also
request a copy of this Disclosure Brochure at any time by contacting the Advisor at 612-256-2208 or by email at
dpilacinski@truevisionadv.com.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 2
Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................... 1
Item 2 – Material Changes ..................................................................................................................................... 2
Item 3 – Table of Contents .................................................................................................................................... 3
Item 4 – Advisory Services ................................................................................................................................... 4
A. Firm Information ............................................................................................................................................................. 4
B. Advisory Services Offered .............................................................................................................................................. 4
C. Client Account Management .......................................................................................................................................... 6
D. Wrap Fee Programs ....................................................................................................................................................... 6
E. Assets Under Management ............................................................................................................................................ 6
Item 5 – Fees and Compensation ......................................................................................................................... 6
A. Fees for Advisory Services ............................................................................................................................................. 6
B. Fee Billing ....................................................................................................................................................................... 7
C. Other Fees and Expenses ............................................................................................................................................. 7
D. Advance Payment of Fees and Termination .................................................................................................................. 8
E. Compensation for Sales of Securities ............................................................................................................................ 8
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 9
Item 7 – Types of Clients ....................................................................................................................................... 9
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................................... 9
A. Methods of Analysis ....................................................................................................................................................... 9
B. Risk of Loss .................................................................................................................................................................. 10
Item 9 – Disciplinary Information ....................................................................................................................... 11
Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 11
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 11
A. Code of Ethics .............................................................................................................................................................. 11
B. Personal Trading with Material Interest ........................................................................................................................ 11
C. Personal Trading in Same Securities as Clients .......................................................................................................... 12
D. Personal Trading at Same Time as Client ................................................................................................................... 12
Item 12 – Brokerage Practices ............................................................................................................................ 12
A. Recommendation of Custodian[s] ................................................................................................................................ 12
B. Aggregating and Allocating Trades .............................................................................................................................. 13
Item 13 – Review of Accounts ............................................................................................................................ 13
A. Frequency of Reviews .................................................................................................................................................. 13
B. Causes for Reviews ..................................................................................................................................................... 13
C. Review Reports ............................................................................................................................................................ 13
Item 14 – Client Referrals and Other Compensation ........................................................................................ 13
A. Compensation Received by True Vision ...................................................................................................................... 13
B. Compensation for Client Referrals ............................................................................................................................... 15
Item 15 – Custody ................................................................................................................................................ 15
Item 16 – Investment Discretion ......................................................................................................................... 15
Item 17 – Voting Client Securities ...................................................................................................................... 15
Item 18 – Financial Information .......................................................................................................................... 15
Form ADV Part 2A – Appendix 1 ........................................................................................................................ 16
Form ADV Part 2B – Brochure Supplements .................................................................................................... 23
Privacy Policy ...................................................................................................................................................... 31
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 3
Item 4 – Advisory Services
A. Firm Information
True Vision MN LLC (“True Vision” or the “Advisor”) is a registered investment advisor with the U.S. Securities and
Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under the laws of the State
of Minnesota. True Vision was founded in January 2019 and is owned and operated by Darin Pilacinski (Founder and
Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business
practices, and the advisory services provided by True Vision.
B. Advisory Services Offered
True Vision offers investment advisory services to individuals, high net worth individuals, trusts, and estates (each
referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the
Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts
of interest. True Vision's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Wealth Management Services
True Vision provides wealth management services for its Clients. These services generally include a broad range of
comprehensive financial planning in connection with discretionary investment management of Client portfolios. These
services are described below.
Investment Management Services
True Vision provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management services. True Vision
works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial
situation in order to create a portfolio strategy. True Vision will then construct an investment portfolio, consisting of
low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”), individual stocks, bonds, and independent
managers to meet the needs of its Clients. The Advisor may retain other types of investments from the Client’s legacy
investments based on portfolio fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified
between the Advisor and the Client.
True Vision’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market conditions.
True Vision will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances,
and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on
the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
True Vision evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. True Vision may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. True Vision may recommend specific positions to increase sector or asset class weightings. The Advisor
may recommend employing cash positions as a possible hedge against market movement.
True Vision may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains
or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting
of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any
risk deemed unacceptable for the Client’s risk tolerance.
At no time will True Vision accept or maintain custody of a Client’s funds or securities, except for the limited authority
as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 4
Third-Party Access Platforms
The Advisor may use third-party platforms to access, aggregate, or manage certain client accounts that are held
away from the Advisor’s primary custodians, such as employer-sponsored retirement plans or other externally
maintained accounts. These platforms allow clients to grant the Advisor authorized access to account information
and, where permitted, limited account management capabilities.
Access to such accounts is provided solely at the client’s direction and subject to the permissions granted by the
client through the third-party platform. Recommendations to have assets managed through a third-party platform
pose a conflict between the interests of the Advisor and the interests of the Client. Assets managed through a third-
party platform increases the level of investment assets with the Advisor, as it would increase the amount of advisory
fees paid to the Advisor. Clients are not obligated to have the Advisor manage held-away assets by the Advisor.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts
or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee
Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws
governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment
advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or
recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another
IRA, or from one type of account to another account (e.g., commission-based account to fee-based account). Such
a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as
a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed
by the Advisor.
Financial Planning Services
True Vision will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written
financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on
their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or
rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or
consulting may encompass one or more areas of need, including but not limited to, personal financial planning, estate
planning, college planning, capital management, investment consulting, tax planning, and insurance needs.
A financial plan developed for the Client will usually include general recommendations for a course of activity or
specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise
their investment programs, commence or alter retirement savings, establish education savings or contribute to
charitable giving programs.
True Vision, with consent by the Client, will typically coordinate with the Client’s existing specialists including an
accountant, attorney, and others. True Vision may also refer a Client to a specialist as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s
financial situation, observations, and recommendations.
Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the
Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment
management services or to increase the level of investment assets with the Advisor, as it would increase the amount
of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the
Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations
made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor.
Use of Independent Managers
True Vision will recommend that a Client utilize one or more unaffiliated investment managers or investment platforms
(collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio. In such instances, the
Client may be required to authorize and enter into an advisory agreement with the Independent Manager[s] that
defines the terms in which the Independent Manager[s] will provide investment management and related services.
The Advisor may also assist in the development of the initial policy recommendations and managing the ongoing
Client relationship. The Advisor will perform initial and ongoing oversight and due diligence over the selected
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 5
Independent Manager[s] to ensure the Independent Managers’ strategies and target allocations remain aligned with
its clients’ investment objectives and overall best interests. The Client, prior to entering into an agreement with
unaffiliated investment manager[s] or investment platform[s], will be provided with the Independent Manager's Form
ADV 2A (or a brochure that makes the appropriate disclosures).
C. Client Account Management
Prior to engaging True Vision to provide investment advisory services, each Client is required to enter into an
agreement with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
• Establishing an Investment Strategy – True Vision, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
• Asset Allocation – True Vision will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – True Vision will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
•
Investment Management and Supervision – True Vision will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
True Vision includes securities transaction fees together with its investment advisory fees. Including these fees into
a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its investment management
services for its Clients. The Advisor sponsors the True Vision Wrap Fee Program solely as a supplemental disclosure
regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular
year, the Client may pay more or less in total fees than if the Client paid its own securities transaction fees. Please
see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure.
E. Assets Under Management
As of December 31, 2025, True Vision manages approximately $271,745,411 in assets under management, all of
which are managed on a discretionary basis. Clients may request more current information at any time by contacting
the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
agreement with the Advisor.
A. Fees for Advisory Services
Wealth Management Services
Investment advisory fees are paid quarterly in advance pursuant to the terms of the investment advisory agreement.
Investment advisory fees are based on the market value of assets under management at the end of the prior calendar
quarter. Investment advisory fees range from 0.30% to 1.50% annually based on several factors, including: the scope
and complexity of the services to be provided; the level of assets to be managed; and the overall relationship with the
Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other
complexities may be charged a higher fee. The investment advisory fee in the first quarter of service is prorated from
the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the
Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All
securities held in accounts managed by True Vision will be independently valued by the Custodian. The Advisor will
conduct periodic reviews of the Custodian’s valuation to ensure accurate billing.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 6
The Client may make additions or withdrawals from the account[s] at any time, subject to the Advisor’s right to terminate
an account or the overall relationship. Additions may be in cash or securities provided that the Advisor reserves the right
to liquidate any transferred securities or decline to accept particular securities into a Client’s account[s]. Clients may
withdraw account assets on notice to True Vision, subject to the usual and customary securities settlement procedures.
However, the Advisor typically designs its investment portfolios as long-term investments and the withdrawal of assets
may impair the achievement of a Client’s investment objectives. True Vision may consult the Client about certain
implications of such transactions. Clients are advised that when such securities are liquidated, they may be subject to
securities transaction fees, short-term redemption fees, and/or tax ramifications. If assets in excess of $10,000 are
deposited into or withdrawn from the Client’s account[s], the Advisor’s fee will be adjusted in the next billing period to
reflect the fee difference. The Advisor, at its sole discretion, will negotiate a fee that differs from the schedule above for
certain account[s] or holdings.
For assets managed through a third-party platform, the Client is not charged any additional platform fees. The Advisor
bears the cost of the platform in order to service these Client assets. Advisory fees apply to assets accessed and
managed through the platform as part of the Client’s assets under management, as disclosed above.
Use of Independent Managers
For Clients accounts implemented through an Independent Manager, the Client’s fee will be deducted from the
Client’s account[s] with the respective Independent Manager and a portion of the fee will be provided to True Vision
based on True Vision’s agreement with the Client. True Vision is responsible for negotiating the fees with the
Independent Manager on behalf of the Client. True Vision does not receive any compensation or fees from the
Independent Manager.
Financial Planning Services
True Vision offers financial planning services for a fixed initial engagement fee, and then hourly fees for subsequent
meetings. Initial fixed fees range from $2,500 to $5,000. Hourly fees range from $285 to $500 per hour. Fees may be
negotiable based on the nature and complexity of the services to be provided and the overall relationship with the
Advisor. An estimate for total hours and/or total costs will be provided to the Client prior to engaging for these
services.
B. Fee Billing
Wealth Management Services
Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the
Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from
the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly
rate (annual rate divided by the number of days in the year multiplied by the number of days in the quarter) to the total
assets under management with True Vision at the end of the prior quarter. Proration is used for deposits or withdrawals
above the $10,000 threshold. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting
deduction of the investment advisory fee. Clients provide written authorization permitting advisory fees to be deducted
by True Vision to be paid directly from their account[s] held by the Custodian as part of the investment advisory
agreement and separate account forms provided by the Custodian.
Use of Independent Managers
For Clients accounts implemented through an Independent Manager, the Client’s fee may be separately billed or
deducted from the Client’s account[s] with the respective manager and a portion of the investment advisory fee may
be provided to True Vision.
Financial Planning Services
Financial planning fees are invoiced by the Advisor and are due upon completion of the agreed upon deliverable[s].
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf of
the Client’s account[s]. The Advisor includes securities transactions costs as part of its overall investment advisory
fee through the True Vision Wrap Fee Program. Securities transaction fees for Client-directed trades may be charged
back to the Client. Please see Item 4.D. as well as Appendix 1 – Wrap Fee Program Brochure.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 7
In addition, all fees paid to True Vision for investment advisory services are separate and distinct from the expenses
charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in
each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds,
other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible
distribution fee. A Client may be able to invest in these products directly, without the services of True Vision, but
would not receive the services provided by True Vision which are designed, among other things, to assist the Client
in determining which products or services are most appropriate for each Client’s financial situation and objectives.
Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by True Vision to
fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information.
D. Advance Payment of Fees and Termination
Wealth Management Services
True Vision may be compensated for its investment management services in advance of the quarter in which services
are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written
notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days
of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for
bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client.
Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of
termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-transferable
without the Client’s prior consent.
Use of Independent Managers
If a Client should wish to terminate their relationship with the Independent Manager, the terms for termination will be
set forth in the respective agreements between the Client and that Independent Manager. True Vision will assist the
Client with the termination and transition as appropriate.
Financial Planning Services
True Vision is compensated for its financial planning services upon completion of the engagement deliverable[s].
Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the
other party. The Client may also terminate the financial planning agreement within five (5) business days of signing
the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide
advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon
termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate
or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. The
Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
True Vision does not buy or sell securities to earn commissions and does not receive any compensation for securities
transactions in any Client account, other than the investment advisory fees noted above.
Broker-Dealer Affiliation
Certain Advisory Persons of the Advisor are also registered representatives of LPL Financial LLC ("LPL Financial"),
a securities broker-dealer, and a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities
Investor Protection Corporation (“SIPC”). In one’s separate capacity as a registered representative of LPL Financial,
an Advisory Person implements securities transactions under LPL Financial and not through the Advisor. In such
instances, an Advisory Person will receive commission- based compensation in connection with the purchase and
sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by an
Advisory Person in one’s capacity as a registered representative is separate and in addition to the Advisor’s advisory
fees. This practice presents a conflict of interest because Advisory Persons who are registered representatives have
an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on
the Client. The Advisor mitigates this conflict in two ways. First, Clients always have the right to choose whether or
not to purchase securities products through an Advisory Person. Second, the Advisor will not charge an ongoing
investment advisory fee on any assets implemented in one’s separate capacity as a registered representative. Please
see Item 10 – Other Financial Industry Activities and Affiliations.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 8
Insurance Agency Affiliation
Certain Advisory Persons are also licensed as independent insurance professionals. As an independent insurance
professional, an Advisory Person may earn commission-based compensation for selling insurance products,
including insurance products offered to Clients. Insurance commissions earned by these persons are separate and
in addition to advisory fees. This practice presents a conflict of interest as an Advisory Persons who is also an
insurance professional will have an incentive to recommend insurance products to the Client for the purpose of
generating commissions rather than solely based on a Client’s needs. Clients are under no obligation, contractual or
otherwise to choose whether or not to purchase insurance products through any Advisory Person affiliated with the
Advisor. Please see Item 10 – Other Financial Industry Activities and Affiliations.
Item 6 – Performance-Based Fees and Side-By-Side Management
True Vision does not charge performance-based fees for its investment advisory services. The fees charged by True
Vision are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities
held by any Client.
True Vision does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund
or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients.
Item 7 – Types of Clients
True Vision offers investment advisory services to individuals, high net worth individuals, trusts, and estates. True
Vision generally does not impose a minimum relationship size.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
True Vision primarily employs a fundamental, technical, and cyclical analysis methods in developing investment
strategies for its Clients. Research and analysis from True Vision are derived from numerous sources, including
financial media companies, third-party research materials, Internet sources, and review of company activities,
including annual reports, prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists
generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed.
Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value
discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does
not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the
fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these
economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s
review process are included below in Item 13 – Review of Accounts.
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. 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 True Vision will be able to accurately predict such a
reoccurrence.
Cyclical analysis is similar to technical analysis in that it involves the analysis of market conditions at a macro (entire
market/economy) or micro (company specific) level, rather than the overall fundamental analysis of the health of the
particular company that True Vision is recommending. The risks with cyclical analysis are similar to those of technical
analysis.
As noted above, True Vision generally employs a long-term investment strategy for its Clients, as consistent with
their financial goals. True Vision will typically hold all or a portion of a security for more than a year, but may hold for
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 9
shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, True Vision
may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the
fundamentals of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should
be prepared to bear the potential risk of loss. True Vision will assist Clients in determining an appropriate strategy
based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet
their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may
lose value and may have negative investment performance. The Advisor monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are
included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process.
Following are some of the risks associated with the Advisor’s investment strategies:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will
fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based
on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread
and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from
the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point
in the day may have a different price than the same ETF purchased or sold a short time later.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall
if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate
of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was
previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds
the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated
with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment
obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating
which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk
that a bond may not be sold as quickly as there is no readily available market for the bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 10
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price
as a mutual fund purchased later that same day.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving True Vision or its owner. True Vision values the
trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any
advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available
on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm
name or CRD# 322783.
Item 10 – Other Financial Industry Activities and Affiliations
Broker-Dealer Affiliation
As noted in Item 5.E above, certain Advisory Persons are also a registered representative of LPL Financial. In their
separate capacity as registered representatives, Advisory Persons will receive commissions for the implementation
of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation
provided by Advisory Persons. Neither the Advisor nor Advisory Persons will earn ongoing investment advisory fees
in connection with any services implemented in an Advisory Person’s separate capacity as a registered
representative.
Insurance Agency Affiliation
As noted in Item 5.E above, certain Advisory Persons are also licensed insurance professionals. Implementations of
insurance recommendations are separate and apart from one’s role with the Advisor. As an insurance professional,
the Advisory Person will receive customary commissions and other related revenues from the various insurance
companies whose products are sold. Advisory Persons are not required to offer the products of any insurance
company. Commissions generated by insurance sales do not offset regular advisory fees. This presents a conflict of
interest in recommending certain products of the insurance companies. Clients are under no obligation to implement
any recommendations made by Advisory Persons or the Advisor.
Use of Independent Managers
As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio with one or more
Independent Managers. The Advisor does not receive any compensation, nor does this present a material conflict of
interest. The Advisor will only earn its investment advisory fee as described in Item 5.A.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
True Vision has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each
Client. This Code applies to all persons associated with True Vision (“Supervised Persons”). The Code was
developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client.
True Vision and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the
obligation of True Vision’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to
the general principles that guide the Code. The Code covers a range of topics that address employee ethics and
conflicts of interest. To request a copy of the Code, please contact the Advisor at 612-256-2208 or via email at
dpilacinski@truevisionadv.com.
B. Personal Trading with Material Interest
True Vision allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. True Vision does not act as principal in any transactions. In addition, the Advisor
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 11
does not act as the general partner of a fund, or advise an investment company. True Vision does not have a material
interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
True Vision allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and
procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public
information controls); gifts and entertainment; outside business activities and personal securities reporting. When
trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The
fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated
by True Vision requiring reporting of personal securities trades by its Supervised Persons for review by the Chief
Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the misuse of
material, non-public information.
D. Personal Trading at Same Time as Client
While True Vision allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At
no time will True Vision, or any Supervised Person of True Vision, transact in any security to the detriment
of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
True Vision does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and
authorize True Vision to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further,
True Vision does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-
trade basis.
Where True Vision does not exercise discretion over the selection of the Custodian, it may recommend the Custodian
to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the
Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by True Vision.
However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged.
True Vision may recommend the Custodian based on criteria such as, but not limited to, reasonableness of
commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the
Custodian’s offices.
True Vision will generally recommend that Clients establish their account[s] at LPL Financial LLC (“LPL”) and Charles
Schwab & Co., Inc. (“Schwab”), FINRA-registered broker-dealers and members SIPC. LPL or Schwab will serve as
the Client’s “qualified custodian”. True Vision maintains an institutional relationship with LPL and Schwab, whereby
the Advisor receives economic benefits. Please see Item 14 below.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters
into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other
services. True Vision does not participate in soft dollar programs sponsored or offered by any broker-
dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see
Item 14 below.
2. Brokerage Referrals - True Vision does not receive any compensation from any third party in connection with the
recommendation for establishing an account.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 12
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where True Vision will place trades
within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded
within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security
from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security
into one Client account from another Client’s account[s]). True Vision will not be obligated to select competitive bids
on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs
are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution,
4) confidentiality and 5) skill required of the Custodian. True Vision will execute its transactions through the Custodian
as authorized by the Client. True Vision may aggregate orders in a block trade or trades when securities are
purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade
cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each
business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement.
This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Darin Pilacinski, Chief Compliance
Officer of True Vision. Formal reviews are generally conducted at least annually or more frequently depending on the
needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually.
Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major
changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or
withdrawals in the Client’s account[s]. The Client is encouraged to notify True Vision if changes occur in the Client’s
personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be
triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements
are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s
website so that the Client may view these reports and their account activity. Client brokerage statements will include
all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with
periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by True Vision
True Vision is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product.
True Vision does not receive commissions or other compensation from product sponsors, broker-dealers or any un-
related third party. True Vision may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys,
accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise,
True Vision may receive non-compensated referrals of new Clients from various third-parties.
Participation in Institutional Advisor Platform - Schwab
True Vision has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a
division of Schwab dedicated to serving independent advisory firms like True Vision. As a registered investment
advisor participating on the Schwab Advisor Services platform, True Vision receives access to software and related
support without cost because the Advisor renders investment management services to Clients that maintain assets
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 13
at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided
by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests
of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates
a potential conflict of interest since these benefits may influence the Advisor’s recommendation of this custodian over
one that does not furnish similar software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able
to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and
other investments without having to adhere to investment minimums that might be required if the Client were to
directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology,
research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts,
the ability to deduct advisory fees, trading tools, and back-office support services as part of its relationship with
Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may
not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services to True Vision that may not benefit
the Client, including: educational conferences and events, consulting services and discounts for various service
providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results
in a potential conflict of interest. True Vision believes, however, that the selection of Schwab as Custodian is in the
best interests of its Clients.
Participation in Institutional Advisor Platform - LPL
True Vision receives support services and/or products from LPL Financial, many of which assist True Vision to better
monitor and service program accounts maintained at LPL Financial; however, some of the services and products
benefit True Vision and not client accounts. These support services and/or products may be received without cost,
at a discount, and/or at a negotiated rate, and may include the following:
investment-related research
software and other technology that provide access to client account data
compliance and/or practice management-related publications
consulting services
computer hardware and/or software
•
• pricing information and market data
•
•
•
• attendance at conferences, meetings, and other educational and/or social events
• marketing support
•
• other products and services used by True Vision in furtherance of its investment advisory business operations
LPL Financial may provide these services and products directly, or may arrange for third party vendors to provide the
services or products to True Vision. In the case of third party vendors, LPL Financial may pay for some or all of the
third party’s fees.
These support services are provided to True Vision based on the overall relationship between True Vision and LPL
Financial. It is not the result of soft dollar arrangements or any other express arrangements with LPL Financial that
involves the execution of client transactions as a condition to the receipt of services. True Vision will continue to
receive the services regardless of the volume of client transactions executed with LPL Financial. Clients do not pay
more for services as a result of this arrangement. There is no corresponding commitment made by the True Vision
to LPL or any other entity to invest any specific amount or percentage of client assets in any specific securities as a
result of the arrangement. However, because Advisor receives these benefits from LPL Financial, there is a potential
conflict of interest. The receipt of these products and services presents a financial incentive for Advisor to recommend
that its clients use LPL Financial’s custodial platform rather than another custodian’s platform.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 14
B. Compensation for Client Referrals
True Vision does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client
referrals.
Item 15 – Custody
The Advisor is authorized to deduct its fees from the Client’s acount at the Custodian. The Clients for whom True
Vision exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for
engaging a “qualified custodian” to retain their funds and securities and must instruct True Vision to utilize that
Custodian for securities transactions on their behalf. Clients should review statements provided by the Custodian as
the Custodian does not perform this review. For more information about custodians and brokerage practices, please
see Item 12 – Brokerage Practices.
For instances where Clients authorize True Vision to move funds between their accounts, the Advisor may have
custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have
implemented safeguards to ensure that all money movement activities are conducted strictly in accordance with the
Client’s instructions.
Item 16 – Investment Discretion
True Vision generally has discretion over the selection and amount of securities to be bought or sold in Client accounts
without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to
specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by True
Vision. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority
will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations
to such authority. All discretionary trades made by True Vision will be in accordance with each Client's investment
objectives and goals.
Item 17 – Voting Client Securities
True Vision does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly
from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the
sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither True Vision, nor its management, have any adverse financial situations that would reasonably impair the
ability of True Vision to meet all obligations to its Clients. Neither True Vision, nor any of its Advisory Persons, have
been subject to a bankruptcy or financial compromise. True Vision is not required to deliver a balance sheet along
with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be
performed six months or more in the future.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 15
True Vision MN LLC dba True Vision Financial Advisors
Form ADV Part 2A – Appendix 1
(“Wrap Fee Program Brochure”)
Effective: February 17, 2026
This Form ADV2A - Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications and
business practices for True Vision MN LLC (“True Vision” or the “Advisor”) services when offering services pursuant
to a wrap program. This Wrap Fee Program Brochure shall always be accompanied by the True Vision Disclosure
Brochure, which provides complete details on the business practices of the Advisor. If you did not receive the
complete True Vision Disclosure Brochure or you have any questions about the contents of this Wrap Fee Program
Brochure or the True Vision Disclosure Brochure, please contact the Advisor at 612-256-2208 or by email at
dpilacinski@truevisionadv.com.
True Vision is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Wrap Fee Program Brochure has not been approved or verified by the SEC or by any state
securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This
Wrap Fee Program Brochure provides information about True Vision to assist you in determining whether to retain
the Advisor.
Additional information about True Vision and its Advisory Persons are available on the SEC’s website at
www.adviserinfo.sec.gov by searching the Advisor’s firm name or CRD# 322783.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 16
Item 2 – Material Changes
Form ADV 2A - Appendix 1 provides information about a variety of topics relating to an Advisor’s business practices
and conflicts of interest. This Wrap Fee Program Brochure discusses the Wrap Fee Program offered by the Advisor.
Material Changes
No material changes have been made to this Wrap Fee brochure since the last annual amendment filing on January
31, 2024.
Future Changes
From time to time, the Advisor may amend this Wrap Fee Program Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete Wrap Fee
Program Brochure (along with the complete True Vision Disclosure Brochure) or a Summary of Material Changes
shall be provided to you annually and if a material change occurs in the business practices of True Vision.
At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at the SEC’s
Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching for the Advisor’s firm name
or CRD# 322783. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at
612-256-2208 or by email at dpilacinski@truevisionadv.com.
Item 3 – Table of Contents
Item 2 – Material Changes ................................................................................................................................... 17
Item 3 – Table of Contents .................................................................................................................................. 17
Item 4 – Services Fees and Compensation ....................................................................................................... 18
Item 5 – Account Requirements and Types of Clients ..................................................................................... 19
Item 6 – Portfolio Manager Selection and Evaluation ...................................................................................... 19
Item 7 – Client Information Provided to Portfolio Managers ........................................................................... 21
Item 8 – Client Contact with Portfolio Managers .............................................................................................. 21
Item 9 – Additional Information .......................................................................................................................... 21
Privacy Policy ...................................................................................................................................................... 31
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 17
Item 4 – Services Fees and Compensation
A. Services
True Vision provides customized investment advisory services for its Clients. This Wrap Fee Program Brochure is
provided as a supplement to the True Vision Disclosure Brochure (Form ADV 2A). This Wrap Fee Program Brochure
is provided along with the complete Disclosure Brochure to provide full details of the business practices and fees
when selecting True Vision as your investment advisor.
As part of the investment advisory fees noted in Item 5 of the Disclosure Brochure, True Vision includes, in addition
to custodial, securities transaction fees, other management costs and expenses (herein “Covered Costs”) as part of
the overall investment advisory fee. Securities regulations often refer to this combined fee structure as a “Wrap Fee
Program”. The Advisor’s recommended Custodian does not charge securities transaction fees for exchange-traded
fund (“ETF”) and equity trades in Client accounts, but typically charges for mutual funds and other types of
investments. The Advisor sponsors the True Vision Wrap Fee Program.
The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination of
Covered Costs into a single “bundled” investment advisory fee. This Wrap Fee Program Brochure references back
to the True Vision Disclosure Brochure in which this Wrap Fee Program Brochure serves as an Appendix. Please
see Item 4 – Advisory Services of the Disclosure Brochure for details on True Vision’s investment philosophy
and related services.
B. Program Costs
Advisory services provided by True Vision are offered in a wrap fee structure whereby Covered Costs are included
in the overall investment advisory fee paid to True Vision. As the level of activity in a Client’s account[s] may vary
from year to year, the annual cost to the Client may be more or less than engaging for advisory services where the
Covered Costs are borne separately by the Client. The cost of the Wrap Fee Program varies depending on services
to be provided to each Client, however, the Client is not charged more if there is higher trading activity or other
Covered Costs. A Wrap Fee structure presents a conflict of interest as the Advisor is incentivized to limit the number
of trades placed in the Client’s account[s] or to utilize securities that do not have transaction fees. As noted above,
the Advisor’s recommended Custodian does not charge securities transaction fees for ETF and equity trades in Client
accounts, but typically charges for mutual funds and other types of investments. As such, the Advisor is incentivized
to utilize ETFs and other equity securities to limit the overall cost to the Advisor. The Advisor will only place Client
assets into a Wrap Fee Program when it is believed to be in the Client’s best interest. Please see Item 5 – Fees and
Compensation of the Disclosure Brochure for complete details on fees.
C. Fees
Wealth Management Services
Investment advisory fees are paid quarterly in advance pursuant to the terms of the investment advisory agreement.
Investment advisory fees are based on the market value of assets under management at the end of the prior calendar
quarter. Investment advisory fees range from 0.30% to 1.50% annually based on several factors, including: the scope
and complexity of the services to be provided; the level of assets to be managed; and the overall relationship with the
Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other
complexities may be charged a higher fee.
The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end
of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by
True Vision will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s
valuation to ensure accurate billing.
The Client may make additions or withdrawals from the account[s] at any time, subject to the Advisor’s right to terminate
an account or the overall relationship. Additions may be in cash or securities provided that the Advisor reserves the right
to liquidate any transferred securities or decline to accept particular securities into a Client’s account[s]. Clients may
withdraw account assets on notice to True Vision, subject to the usual and customary securities settlement procedures.
However, the Advisor typically designs its investment portfolios as long-term investments and the withdrawal of assets
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 18
may impair the achievement of a Client’s investment objectives. True Vision may consult the Client about certain
implications of such transactions. Clients are advised that when such securities are liquidated, they may be subject to
securities transaction fees, short-term redemption fees, and/or tax ramifications. If assets in excess of $10,000 are
deposited into or withdrawn from the Client’s account[s], the Advisor’s fee will be adjusted in the next billing period to
reflect the fee difference. The Advisor, at its sole discretion, will negotiate a fee that differs from the schedule above for
certain account[s] or holdings.
As noted above, the Wrap Fee Program includes Covered Costs incurred in connection with the discretionary
investment management services provided by True Vision, as part of its overall investment advisory fee.
In addition, all fees paid to True Vision for investment advisory services or part of the Wrap Fee Program are separate
and distinct from the expenses charged by mutual funds and exchange-traded funds to their shareholders, if
applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will
generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody,
brokerage and account reporting), and a possible distribution fee. Securities transaction fees for Client-directed trades
will be charged back to the Client. In connection with the discretionary investment management services provided by
True Vision, the Client will incur other costs assessed by the Custodian or other third parties, other than the Covered
Costs noted above, such as wire transfer fees, fees for trades executed away from the Custodian and other fees
such as transfer taxes, odd-lot differentials, certificate delivery fees, reorganization fees, and other fees required by
law. The Advisor does not control nor share in these fees. The Client should review both the fees charged by the
fund[s] and the fees charged by True Vision to fully understand the total fees to be paid. Please see Item 5.C. – Other
Fees and Expenses in the Disclosure Brochure (included with this Wrap Fee Program Brochure).
D. Compensation
True Vision is the sponsor and portfolio manager of this Wrap Fee Program. True Vision receives investment advisory
fees paid by Clients for participating in the Wrap Fee Program and pays the Covered Costs associated with the
management of the Client’s account[s].
Item 5 – Account Requirements and Types of Clients
True Vision offers comprehensive wealth management services to individuals, high net worth individuals, trusts, and
estates. True Vision generally does not impose a minimum account size for establishing a relationship. Please see
Item 7 – Types of Clients in the Disclosure Brochure for additional information.
Item 6 – Portfolio Manager Selection and Evaluation
Portfolio Manager Selection
True Vision serves as sponsor and as portfolio manager for the services under this Wrap Fee Program.
Related Persons
True Vision personnel serve as portfolio managers for this Wrap Fee Program. True Vision does not serve as a
portfolio manager for any third-party Wrap Fee Programs.
Performance-Based Fees
True Vision does not charge performance-based fees for its investment advisory services. The fees charged by True
Vision are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities
held by any Client.
Supervised Persons
True Vision Advisory Persons serve as portfolio managers for all accounts, including the services described in this
Wrap Fee Program Brochure. Details of the advisory services provided are included in Item 4.A. of the Disclosure
Brochure.
Methods of Analysis
Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on the
research and analysis methods employed by the Advisor.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 19
Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should
be prepared to bear the potential risk of loss. True Vision will assist Clients in determining an appropriate strategy
based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet
their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may
lose value and may have negative investment performance. The Advisor monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are
included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process.
Following are some of the risks associated with the Advisor’s investment strategies:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will
fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based
on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread
and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from
the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point
in the day may have a different price than the same ETF purchased or sold a short time later.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall
if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate
of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was
previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds
the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated
with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment
obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating
which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk
that a bond may not be sold as quickly as there is no readily available market for the bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price
as a mutual fund purchased later that same day.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 20
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor. Please see Item 8.B. – Risk of Loss in the Disclosure Brochure for details on
investment risks.
Proxy Voting
True Vision does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly
from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the
sole responsibility for proxy decisions and voting.
Item 7 – Client Information Provided to Portfolio Managers
True Vision is the sponsor and sole portfolio manager for the Program. The Advisor does not share Client information
with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program. Please also see
the True Vision Privacy Policy (included after this Wrap Fee Program Brochure).
Item 8 – Client Contact with Portfolio Managers
True Vision is a full-service investment management advisory firm. Clients always have direct access to the Portfolio
Managers at True Vision.
Item 9 – Additional Information
A. Disciplinary Information and Other Financial Industry Activities and Affiliations
There are no legal, regulatory or disciplinary events involving True Vision or its owner. True Vision values the
trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any
advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available
on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm
name or CRD# 322783.
Please see Item 9 of the True Vision Disclosure Brochure as well as Item 3 of each Advisory Person’s Brochure
Supplement (included with this Wrap Fee Program Brochure) for additional information on how to research the
background of the Advisor and its Advisory Persons.
Other Financial Activities and Affiliations
Please see Item 10 – Other Financial Activities and Affiliation and Item 14 – Client Referrals and Other Compensation
of the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program Brochure).
B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information
True Vision has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each Client. This
Code of Ethics applies to all persons subject to True Vision’s compliance program (our “Supervised Persons”).
Complete details on the True Vision Code of Ethics can be found under Item 11 – Code of Ethics, Participation in
Client Transactions and Personal Trading in the Disclosure Brochure (included with this Wrap Fee Program
Brochure).
Investments in
Review of Accounts
Client accounts are monitored on a regular and continuous basis by Advisory Persons of True Vision under the
supervision of the Chief Compliance Officer (“CCO”). Details of the review policies and practices are provided in
Item 13 of the Form ADV Part 2A – Disclosure Brochure.
Participation in Institutional Advisor Platform - Schwab
True Vision has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a
division of Schwab dedicated to serving independent advisory firms like Prospect Financial. As a registered
investment advisor participating on the Schwab Advisor Services platform, True Vision receives access to software
and related support without cost because the Advisor renders investment management services to Clients that
maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 21
services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times
to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a
custodian creates a potential conflict of interest since these benefits may influence the Advisor’s recommendation of
this custodian over one that does not furnish similar software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able
to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and
other investments without having to adhere to investment minimums that might be required if the Client were to
directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology,
research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts,
the ability to deduct advisory fees, trading tools, and back-office support services as part of its relationship with
Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may
not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services to True Vision that may not benefit
the Client, including: educational conferences and events, consulting services and discounts for various service
providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results
in a potential conflict of interest. True Vision believes, however, that the selection of Schwab as Custodian is in the
best interests of its Clients.
Participation in Institutional Advisor Platform - LPL
The Advisor has established an institutional relationship with LPL Financial to assist the Advisor in managing Client
account[s]. The Advisor receives access to software and related support as part of its relationship with LPL Financial.
The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to
its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however,
that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence
the Advisor's recommendation of the Custodian over one that does not furnish similar software, systems support, or
services. Additionally, the Advisor may receive the following benefits from LPL Financial: receipt of duplicate Client
confirmations and bundled duplicate statements; access to a trading desk that exclusively services its 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 14 – Other Compensation in the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program
Brochure) for details on additional compensation that may be received by True Vision or its Advisory Persons. Each
Advisory Person’s Brochure Supplement (also included with this Wrap Fee Program Brochure) provides details on
any outside business activities and the associated compensation.
Compensation for Client Referrals
True Vision does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client
referrals.
Financial Information
True Vision, nor its management, have any adverse financial situations that would reasonably impair the ability of
True Vision to meet all obligations to its Clients. Neither True Vision, nor any of its Advisory Persons, have been
subject to a bankruptcy or financial compromise. True Vision is not required to deliver a balance sheet along with
this Disclosure Brochure as the Advisor does not collect advance fees of $500 or more for services to be performed
six months or more in the future.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 22
Form ADV Part 2B – Brochure Supplement
for
Darin W. Pilacinski
Founder, Chief Compliance Officer, and Financial Advisor
Effective: February 17, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Darin
W. Pilacinski (CRD# 2836851) in addition to the information contained in the True Vision MN LLC (“True Vision” or
the “Advisor”, CRD# 322783) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if
you have any questions about the contents of the True Vision Disclosure Brochure or this Brochure Supplement,
please contact us at 612-256-2208 or by email at dpilacinski@truevisionadv.com.
Additional information about Mr. Pilacinski is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2836851.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 23
Item 2 – Educational Background and Business Experience
Darin W. Pilacinski, born in 1968, is dedicated to advising Clients of True Vision as the Founder, Chief Compliance
Officer, and Financial Advisor. Mr. Pilacinski earned a Bachelors of Arts from St Johns University in 1992. Additional
information regarding Mr. Pilacinski’s employment history is included below.
Employment History:
Founder, Chief Compliance Officer, and Financial Advisor, True Vision MN LLC 09/2022 to Present
07/2019 to Present
Registered Representative, LPL Financial LLC
02/2019 to 09/2022
Financial Advisor, Gladstone Wealth Partners
05/2016 to 02/2019
Financial Advisor, Financial Engines Advisors, LLC
07/2015 to 12/2016
Financial Advisor, Financial Engines Advisor Center LLC
08/2010 to 07/2015
Financial Advisor, The Mutual Fund Store
Chartered Mutual Fund Counselor™ (“CMFC®”)
The Chartered Mutual Fund Counselor™ (CMFC®) is the professional credential awarded by the College for Financial
Planning for financial services professionals. The College for Financial Planning collaborated with the Investment
Company Institute™(ICI®), the primary trade organization for the mutual fund industry, to create this program in 1996.
To complete the program, candidates typically study for 9-11 weeks and have to successfully pass the course’s final
exam at one of their (College for Financial Planning™) centers: PSI, Prometric, or ISO Quality Testing. Successful
applicants earn the right to use the CMFC® with their names for two years. Every two years, CMFC® professionals
must complete 16 hours of continuing education to continue using the designation.
The study program to become a CMFC® covers types and characteristics of open and closed-end funds, other
packaged investment products, risk and return, asset allocation, selecting a mutual fund for a client, retirement
planning, and professional conduct.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Pilacinski. Mr. Pilacinski has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Pilacinski.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud;
false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or
extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or
disciplinary events to disclose regarding Mr. Pilacinski.
However, we do encourage you to independently view the background of Mr. Pilacinski on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
2836851.
Item 4 – Other Business Activities
Broker-Dealer Affiliation
Mr. Pilacinski is also a registered representative of LPL Financial LLC (“LPL Financial”). LPL Financial is a registered
broker-dealer (CRD# 6413), member FINRA, SIPC. In Mr. Pilacinski’s separate capacity as a registered
representative, Mr. Pilacinski will receive commissions for the implementation of recommendations for
commissionable transactions. Clients are not obligated to implement any recommendation provided by Mr. Pilacinski.
Neither the Advisor nor Mr. Pilacinski will earn ongoing investment advisory fees in connection with any products or
services implemented in Mr. Pilacinski’s separate capacity as a registered representative. Mr. Pilacinski spends
approximately 5% of his time per month in his role as a registered representative of LPL Financial.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 24
Insurance Agency Affiliations
Mr. Pilacinski is also a licensed insurance professional. Implementations of insurance recommendations are separate
and apart from Mr. Pilacinski’s role with True Vision. As an insurance professional, Mr. Pilacinski will receive
customary commissions and other related revenues from the various insurance companies whose products are sold.
Mr. Pilacinski is not required to offer the products of any particular insurance company. Commissions generated by
insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any recommendations
made by Mr. Pilacinski or the Advisor. Mr. Pilacinski spends approximately 5% of his time per month in this capacity.
Item 5 – Additional Compensation
Mr. Pilacinski has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Pilacinski serves as the Founder, Chief Compliance Officer, and Financial Advisor of True Vision. Mr. Pilacinski
can be reached at 612-256-2208.
True Vision has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person
in meeting their fiduciary obligations to Clients of True Vision. Further, True Vision is subject to regulatory oversight
by various agencies. These agencies require registration by True Vision and its Supervised Persons. As a registered
entity, True Vision is subject to examinations by regulators, which may be announced or unannounced. True Vision
is required to periodically update the information provided to these agencies and to provide various reports regarding
the business activities and assets of the Advisor.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 25
Form ADV Part 2B – Brochure Supplement
for
Nathan A. Pribyl
Partner, Financial Advisor
Effective: February 17, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Nathan
A. Pribyl (CRD# 5835667) in addition to the information contained in the True Vision MN LLC (“True Vision” or the
“Advisor”, CRD# 322783) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you
have any questions about the contents of the True Vision Disclosure Brochure or this Brochure Supplement, please
contact us at 612-256-2208 or by email at dpilacinski@truevisionadv.com.
Additional information about Mr. Pribyl is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5835667.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 26
Item 2 – Educational Background and Business Experience
Nathan A. Pribyl, born in 1987, is dedicated to advising Clients of True Vision as a Financial Advisor. Mr. Pribyl
earned a B.S. in Business Management from The University of Phoenix in 2011. Additional information regarding Mr.
Pribyl’s employment history is included below.
Employment History:
Financial Advisor, True Vision MN, LLC
Financial Planner, Gladstone Institutional Advisory, LLC
Financial Planner, Financial Engines Advisors, LLC
09/2022 to Present
01/2021 to 09/2022
11/2016 to 01/2021
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Pribyl. Mr. Pribyl has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Pribyl.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud;
false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or
extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or
disciplinary events to disclose regarding Mr. Pribyl.
However, we do encourage you to independently view the background of Mr. Pribyl on the Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5835667.
Item 4 – Other Business Activities
Allied Partners
Mr. Pribyl is also the owner of Allied Partners, a home building and construction company. This is a non-investment
related venture for which Mr. Pribyl spends approximately 20 hours per week during trading hours fulfilling accounting
and ownership responsibilities. Mr. Pribyl primarily works out of the office, however he is available for appointments
upon request. The Advisor has allocated sufficient resources to support the ongoing needs of Mr. Pribyl’s Clients.
Item 5 – Additional Compensation
Mr. Pribyl has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Pribyl serves as a Financial Advisor of True Vision and is supervised by Darin Pilacinski, the Chief Compliance
Officer. Mr. Pilacinski can be reached at 612-256-2208.
True Vision has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person
in meeting their fiduciary obligations to Clients of True Vision. Further, True Vision is subject to regulatory oversight
by various agencies. These agencies require registration by True Vision and its Supervised Persons. As a registered
entity, True Vision is subject to examinations by regulators, which may be announced or unannounced. True Vision
is required to periodically update the information provided to these agencies and to provide various reports regarding
the business activities and assets of the Advisor.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 27
Form ADV Part 2B – Brochure Supplement
for
Christine M. Thomas, CFP®, CPA
Partner, Financial Advisor
Effective: February 17, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Christine M. Thomas, CFP®,CPA (CRD# 6485808) in addition to the information contained in the True Vision MN
LLC (“True Vision” or the “Advisor”, CRD# 322783) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the True Vision Disclosure Brochure or this
Brochure Supplement, please contact us at 612-256-2208 or by email at dpilacinski@truvisionadv.com.
Additional information about Mrs. Thomas is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 6485808.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 28
Item 2 – Educational Background and Business Experience
Christine M. Thomas, CFP®, CPA, born in 1971, is dedicated to advising Clients of True Vision as a Financial
Advisor. Mrs. Thomas earned an MBA from Metropolitan State University in 2006. Mrs. Thomas also earned a BS
in Accounting from Minnesota State University Moorhead in 1995. Mrs. Thomas also earned an AA in Accounting
from Minnesota North College - Mesabi Range Campus in 1992. Additional information regarding Mrs. Thomas’s
employment history is included below.
Employment History:
11/2023 to Present
07/2020 to 11/2023
09/2015 to 11/2023
03/2018 to 07/2020
Financial Advisor, True Vision MN LLC
Investment Advisor Representative, Berger Financial Group
Tax Advisor, Berger Financial Group
Investment Advisor Representative, Cambridge Investment Research Advisors,
Inc.
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
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 Certified
Financial Planner Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to
hold CFP® certification. It is recognized in the United States and a number of 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. Currently, more than 71,000 individuals have
obtained CFP® certification in the United States.
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 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 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 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 in order
to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary standard of
care. This means CFP® professionals must provide financial planning services in the best interests of their
clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP® Board’s
enforcement process, which could result in suspension or permanent revocation of their CFP® certification.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 29
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mrs. Thomas. Mrs. Thomas has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mrs. Thomas.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mrs. Thomas.
However, we do encourage you to independently view the background of Mrs. Thomas on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD#
6485808.
Item 4 – Other Business Activities
My Book, LLC
Mrs. Thomas is the President and Owner of My Book, LLC. My Book, LLC publishes books and other forms of
online media on different self-help topics. Mrs. Thomas spends approximately 40 hours per month in this role.
Item 5 – Additional Compensation
Mrs. Thomas has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mrs. Thomas serves as a Financial Advisor of True Vision and is supervised by Darin Pilacinski, the Chief
Compliance Officer. Mr. Pilacinski can be reached at 612-256-2208.
True Vision has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of True Vision. Further, True Vision is subject to regulatory
oversight by various agencies. These agencies require registration by True Vision and its Supervised Persons. As a
registered entity, True Vision is subject to examinations by regulators, which may be announced or unannounced.
True Vision is required to periodically update the information provided to these agencies and to provide various
reports regarding the business activities and assets of the Advisor.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 30
Privacy Policy
Effective: February 17, 2026
Our Commitment to You
True Vision MN LLC (“True Vision” or the “Advisor”) is committed to safeguarding the use of personal information of
our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our
Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your private
information, and we do everything that we can to maintain that trust. True Vision (also referred to as "we", "our" and
"us”) protects the security and confidentiality of the personal information we have and implements controls to ensure
that such information is used for proper business purposes in connection with the management or servicing of our
relationship with you.
True Vision does not sell your non-public personal information to anyone. Nor do we provide such information to
others except for discrete and reasonable business purposes in connection with the servicing and management of
our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth
in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how
we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal information
and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s
personal information.
We require third parties that assist in providing our services to you to protect the personal information they receive
from us.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 31
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
to: processing
No
Not Shared
Yes
Yes
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide agreed
upon services to you, consistent with applicable law, including but not
limited
transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
Marketing Purposes
True Vision does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with financial
institutions where you are a customer and where True Vision or the client
has a formal agreement with the financial institution. We will only share
information for purposes of servicing your accounts, not for
marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and persons
that we believe to be your authorized agent[s] or representative[s].
No
Not Shared
Information About Former Clients
True Vision does not disclose and does not intend to disclose, non-public
personal information to non-affiliated third parties with respect to persons
who are no longer our Clients.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal
information other than as described in this notice unless we first notify you and provide you with an opportunity to
prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting
us at 612-256-2208.
True Vision MN LLC
7616 Currell Blvd, Suite 220, Woodbury, MN 55125
Phone: 612-256-2208 * Fax: 612-200-3809
http://www.truevisionadvice.com/
Page 32