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Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure
Form ADV, Part 2A, Item 1
Cover Page
254 WINTON BLOUNT LOOP
MONTGOMERY, ALABAMA 36117
Tel: (334) 277-0500
Fax: (334) 277-8564
March 16, 2026
FORM ADV PART 2A APPENDIX 1
WRAP FEE PROGRAM BROCHURE
This brochure provides information about the qualifications and business practices of Tucker
Financial Group. If you have any questions about the contents of this brochure, please contact
us at (334) 277-0500. The information in this brochure has not been approved or verified by the
United States Securities and Exchange Commission or by any state securities authority.
Additional information about Tucker Financial Group is also available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for Tucker Financial Group is
298292.
Tucker Financial Group is a Registered Investment Adviser. Registration with the United States
Securities and Exchange Commission or any state securities authority does not imply a certain
level of skill or training.
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Form ADV, Part 2A Appendix 1, Item 2
Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure. Each year, we will ensure that
you receive a summary of any material changes to this and subsequent brochures by April 30th.
We will further provide you with our most recent brochure at any time at your request, without
charge. You may request a brochure by contacting us at (334) 277-0500.
Tucker Financial Group was established as a new Registered Investment Advisor in September
2018. Tucker Financial Group is a Registered Investment Advisor with U.S. Securities and
Exchange Commission.
Material Changes since the Last Update was filed on March 14, 2025:
• None
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Form ADV, Part 2A Appendix 1, Item 3
Table of Contents
Item 1 - Cover Page………………………………………………………….……1
Item 2 - Material Changes……………………………………….……………….2
Item 3 - Table of Contents……………………………………………………….3
Item 4 - Services, Fees and Compensation….………………………….……4
Item 5 - Account Requirements and Types of Clients.……………………..7
Item 6 - Portfolio Manager Selection and Evaluation.………………………7
Item 7 - Client Information Provided to Portfolio Managers....…….…….11
Item 8 - Client Contact With Portfolio Managers.…………………………..12
Item 9 - Additional Information…….………………………………………….12
Item 10 - Requirements for State-Registered Advisers…………………..14
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Form ADV Part 2A Appendix 1, Item 4
Services, Fees and Compensation
Tucker Financial Group (hereinafter referred to as "TFG") is a Registered Investment Adviser
based in Montgomery, Alabama. Founded in 2018, Tucker Financial Group provides
investment advice and portfolio management services on a continuing basis, which may
include the review of client investment objectives and goals, recommending asset allocation
strategies of managed assets among investment products such as cash, stocks, mutual funds
and bonds, annuities, and/or preparing written investment strategies. Our investment advice is
tailored to meet our clients’ needs and investment objectives. Clients may impose restrictions
on investing in certain securities or types of securities (such as a product type, specific
companies, specific sectors, etc.) by providing a signed and dated written notification, of
which an e-mail is also an acceptable form of notification. If a client chooses to notify TFG of
investment restrictions via e-mail, it must be understood that TFG will not be held responsible
for the terms of the notification until TFG acknowledges receipt of the notification by e-mail
to the client. This is to prevent there being a miscommunication between the client and TFG in
an instance where an e-mail is either not received or is not seen by the staff of TFG. Should
there ever be an instance where TFG makes a transaction that is in conflict with the client's
revised investment restrictions prior to receiving said notification, the staff of TFG will consult
with the client to determine the best course of action. TFG also provides financial planning
consulting services including risk assessment/management, investment planning, estate
planning, financial organization, or financial decision making/negotiation and retirement
planning.
A “wrap fee program” for purposes of the SEC is a program under which investment advisory
and brokerage execution services are provided for a single “wrapped” fee that is not based on
the transactions in a client account. TFG provides discretionary and non-discretionary
investment advisory services to some of its clients through a managed account program (“the
Wrap Fee Program”). TFG will assist clients in determining the suitability of the Wrap Fee
Program for the client.
In order for TFG to provide asset management services, we request you utilize the brokerage
and custodial services of Charles Schwab and Co. Inc. member FINRA/SIPC (“Schwab”) or
American Funds, for which we have existing relationships. Schwab, American Funds and
Tucker Financial Group are separate companies and not affiliated.
WRAP FEE PROGRAM
TFG’s Wrap Fee Program is offered as a part of the Asset Management Services described
above. TFG provides portfolio management services for this program based on the Client’s
investment goals and objectives. Managed Accounts are available to primarily individuals,
small businesses, pension and profit sharing plans, and charitable organizations.
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Fees and Compensation
The following types of fees will be assessed:
Asset Management – Fees are charged in advance and are based primarily on asset size and the
level of complexity of the services provided. In individual cases, TFG has the sole discretion to
negotiate fees that are lower than the standard fee shown or to waive fees. Fees are not based on
the share of capital gains or capital appreciation of the funds or any portion of the funds.
Comparable services for lower fees may be available from other sources. Fees for the initial
quarter will be prorated based upon the number of calendar days in the calendar quarter that the
advisory agreement is in effect. Fees are based on the market value of the assets on the last
business day of the previous quarter. Annual fees range from .60% - 1.00% depending on the
amount of assets under management (“AUM”) – See chart below. Consulting services are
included in these fees for asset management services with the exception of unique circumstances
that may require a separate agreement for financial planning services (description and fees are
discussed below). If the situation warrants separate financial planning fees, it will be discussed
upfront and a separate agreement will be negotiated.
Fee Schedule for Asset Management:
Total Account Value
Maximum Annual Advisory Fee
Under $1,000,000
$1,000,000 - $1,999,999
$2,000,000 - $4,999,999
$5,000,000 - $24,999,999
$25,000,000 or more
1.00%
1.00%
0.80%
0.70%
0.60%
As authorized in the client agreement, the account custodian withdraws TFG’s advisory fees
directly from the clients’ accounts according to the custodian’s policies, practices, and
procedures. The custodian in turn remits these fees to TFG. The custodial statement includes
the amount of any fees paid directly to TFG to manage the account. Clients may also choose to
be billed for TFG’s advisory fees and pay the fees by check. Tucker Financial Group also sends
quarterly invoices detailing the manner and amount of advisory fees to all clients. You should
compare the statement we send to your custodian/broker-dealer’s statement and verify the
calculation of fees. Your custodian/broker-dealer does not verify the accuracy of fees
calculations. If the account does not contain sufficient funds to pay advisory fees, TFG has
limited authority to sell or redeem securities in sufficient amounts to pay advisory fees. With the
exception of IRA accounts, clients may reimburse the account for advisory fees paid to TFG.
Fees are charged in advance on a quarterly basis, meaning that advisory fees for a quarter are
charged on the first day of the quarter. Clients may terminate investment advisory services
obtained from TFG, without penalty, upon written notice within five (5) business days after
entering into the advisory agreement with TFG. The client is responsible for any fees and
charges incurred by the client from third parties as a result of maintaining the account such as
transaction fees for any securities transactions executed and account maintenance or custodial
fees. Thereafter, the client may terminate advisory services upon written notice delivered to and
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received by TFG. Clients who terminate investment advisory services during a quarter are
charged a prorated advisory fee based on the date of TFG’s receipt of client’s written notice to
terminate. Any earned but unpaid fees are immediately due and payable.
Financial Planning – Financial planning services are charged in arrears through a fixed fee
arrangement as agreed upon between the client and TFG. There will never be an instance where
$1200 or more in fees is charged six or more months in advance. Fees are negotiable and vary
depending upon the complexity of the client situation and services to be provided. Fixed fees are
$100 - $200 per plan. Similar financial planning services may be available elsewhere for a lower
cost to the client.
Clients may be invoiced monthly for all time spent by TFG as agreed upon by client or upon
completion of the services if more than a month. Clients who wish to terminate the planning
process prior to completion may do so with written notice. Upon receipt of written notification,
any earned fee will immediately become due and payable. A client may terminate an advisory
agreement without being assessed any fees or expenses within five (5) days of its signing.
Additional Fees and Expenses
In addition to advisory fees paid to TFG as explained above, clients are charged custodial
service, account maintenance, transaction, and other fees associated with maintaining the
account, however TFG pays some or all of these fees for designated Wrap Accounts. Therefore,
these fees are included in the fee schedule above. These fees vary by broker dealer and/or
custodian. Additionally, for any mutual funds purchased, the client may pay their proportionate
share of the funds’ distribution, internal management, investment advisory and administrative
fees. Such fees are not shared with TFG and are compensation to the fund manager. Clients are
urged to read the mutual fund prospectus prior to investing.
Mutual fund companies impose internal fees and expenses on clients. These fees are in addition
to the costs associated with the investment advisory services as described above. Complete
details of such internal expenses are specified and disclosed in each mutual fund company’s
prospectus. Clients are strongly advised to review the prospectus(es) prior to investing in such
securities.
Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that
would not exist if the purchase or sale were made directly with the mutual fund company.
Mutual funds held in broker-dealer accounts also charge management fees. These mutual fund
management fees may be more or less than the mutual fund management fees charged if the
client held the mutual fund directly with the mutual fund company.
Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal
underwriter, or a distributor without purchasing the services of TFG or paying the advisory fee
on such shares (but subject to any applicable sales charges). Certain mutual funds are offered to
the public without a sales charge. In the case of mutual funds offered with a sales charge, the
prevailing sales charge (as described in the mutual fund prospectus) may be more or less than the
applicable advisory fee. However, clients would not receive TFG’s assistance in developing an
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investment strategy, selecting securities, monitoring performance of the account, and making
changes as necessary.
Form ADV, Part 2A Appendix 1, Item 5
Account Requirements and Types of Clients
TFG offers investment advisory services primarily to individuals, small businesses, pensions and
profit sharing plans and charitable organizations. There is no minimum account size to open and
maintain an advisory account.
Form ADV, Part 2A Appendix 1, Item 6
Portfolio Manager Selection and Evaluation
TFG may act as the portfolio manager and sponsor for its Wrap Fee Program accounts. There is
no conflict of interest with the arrangement.
Advisory Business
Tucker Financial Group (hereinafter referred to as "TFG") is a Registered Investment Adviser
based in Montgomery, Alabama. Founded in 2018, Tucker Financial Group provides investment
advice and portfolio management services on a continuing basis, which may include the review
of client investment objectives and goals, recommending asset allocation strategies of managed
assets among investment products such as cash, stocks, mutual funds and bonds, annuities,
and/or preparing written investment strategies. Our investment advice is tailored to meet our
clients’ needs and investment objectives. Clients may impose restrictions on investing in certain
securities or types of securities (such as a product type, specific companies, specific sectors, etc.)
by providing a signed and dated written notification, of which an e-mail is also an acceptable
form of notification. If a client chooses to notify TFG of investment restrictions via e-mail, it
must be understood that TFG will not be held responsible for the terms of the notification until
TFG acknowledges receipt of the notification by e-mail to the client. This is to prevent there
being a miscommunication between the client and TFG in an instance where an e-mail is either
not received or is not seen by the staff of TFG. Should there ever be an instance where TFG
makes a transaction that is in conflict with the client's revised investment restrictions prior to
receiving said notification, the staff of TFG will consult with the client to determine the best
course of action. TFG also provides financial planning consulting services including risk
assessment/management, investment planning, estate planning, financial organization, or
financial decision making/negotiation and retirement planning.
Tucker Financial Group provides investment advisory and other financial services through its
Investment Advisory Representatives ("IAR") to accounts opened with Tucker Financial Group.
Managed Accounts are available to individuals, small businesses, profit sharing plans and
charitable organizations.
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Asset Management
Tucker Financial Group provides discretionary and non-discretionary investment advisory
services to some of its clients through various managed account programs. Tucker Financial
Group will assist clients in determining the suitability of the Managed Account Programs for the
client. The IAR is compensated through a comprehensive single fee and the account may be
assessed other charges associated with conducting a brokerage business. The firm and its IAR, as
appropriate, will be responsible for the following:
• Performing due diligence
• Recommending strategic asset and style allocations
• Providing research on investment product options, as needed
• Providing client risk profile questionnaire
• Obtaining investment advisory contract from client with required financial, risk tolerance,
suitability and investment vehicle selection information for each new account
• Performing client suitability check on account documentation, reviewing the investment
objectives and evaluating the investment vehicle selections
• Providing Firm Brochure (this document)
TFG may recommend a Wrap Fee Program for the client’s account(s). A “Wrap Fee Program”
for purposes of the SEC is a program under which investment advisory and brokerage execution
services are provided for a single “wrapped” fee that is not based on the transactions in a client
account. TFG provides discretionary investment advisory services to some of its clients through
a Wrap Fee Program. TFG will assist clients in determining the suitability of the Wrap Fee
Program for the client. Wrap Fee Program accounts recommended by TFG are not managed
differently from non-Wrap Fee Program accounts. Because brokerage execution costs are
included in the client’s overall advisory fee, the client’s fee may be greater than those that have
accounts in non-Wrap Fee Program accounts, however fees will not exceed the fee schedule
stated in this Wrap Fee Brochure. All clients with Wrap Fee Program accounts will be provided
with this Wrap Fee Brochure. This Brochure is focused on Wrap Fee Program accounts.
The firm has the following Assets Under Management as of February 25, 2026:
Discretionary Assets Under Management: $339,025,322
Non-Discretionary Assets Under Management: $0
Performance-Based Fees and Side By Side Management
TFG does not charge performance-based fees or participate in side-by-side management. Side-
by-side management refers to the practice of managing accounts that are charged performance-
based fees while at the same time managing accounts that are not charged performance-based
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fees. Performance-based fees are fees that are based on a share of capital gains or appreciation
of the assets of a client. Our fees are calculated as described in Fees and Compensation section
above and are not charged on the basis of performance of your advisory account.
Methods of Analysis, Investment Strategies, and Risk of Loss
TFG’s methods of analysis and investment strategies incorporate the client’s needs and
investment objectives, time horizon, and risk tolerance. TFG is not bound to a specific
investment strategy for the management of investment portfolios, but rather consider the risk
tolerance range of each portfolio and the risk level of each level when the account is opened.
Examples of methodologies that our investment strategies may incorporate include:
Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix
of asset classes and the efficient allocation of capital to those assets by matching rates of return
to a specified and quantifiable tolerance for risk. Asset Allocation has the potential of all the
risks listed below.
Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount
of securities at regularly scheduled intervals, regardless of the price per share. This will
gradually, over time, decrease the average share price of the security. Dollar-cost averaging
lessens the risk of investing a large amount in a single investment at the wrong time. Dollar-Cost
Averaging has the potential of all the risks listed below.
Technical Analysis – involves studying past price charts, patterns and trends in the financial
markets to predict the direction of both the overall market and specific stocks. Technical
Analysis has the potential of all the risks listed below.
Long-Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year. Long-
Term Purchases have the potential of all the risks listed below.
Short-Term Purchases – securities purchased with the expectation that they will be sold within
a relatively short period of time, generally less than one year, to take advantage of the securities’
short term price fluctuations. Short-term Purchases primarily have the potential of Market Risk,
Business Risk, and Liquidity Risk as listed below.
Our strategies and investments may have unique and significant tax implications. Regardless of
your account size or other factors, we strongly recommend that you continuously consult with a
tax professional prior to and throughout the investing of your assets.
Investing in securities involves risk of loss that clients should be prepared to bear. Although we
manage your portfolio with strategies and in a manner consistent with your risk tolerances, there
can be no guarantee that our efforts will be successful. You should be prepared to bear the risk
of loss.
All investments involve the risk of loss, including (among other things) loss of principal, a
reduction in earnings (including interest, dividends, and other distributions), and the loss of
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future earnings. Regardless of the methods of analysis or strategies suggested for your particular
investment goals, you should carefully consider these risks, as they all bear risks.
TFG’s primary goal for investing is to help the client maintain purchasing power over the long
term. This may result in short term variability and loss of principal. Time horizon and risk
tolerance are key determinates of the proper asset allocation. TFG’s approach focuses on taking
appropriate risks for which clients are compensated (i.e., market risk) and seeking to limit or
eliminate risks that do not provide compensation over the long term (i.e., individual stock risk or
lack of portfolio risk).
Below are some more specific risks of investing:
Market Risk. The prices of securities in which clients invest may decline in response to certain
events taking place around the world, including those directly involving the companies whose
securities are owned by the client or an underlying fund; conditions affecting the general
economy; overall market changes; local, regional or global political, social or economic
instability; and currency, interest rate and commodity price fluctuations. Investors should have a
long-term perspective and be able to tolerate potentially sharp declines in market value.
Management Risk. TFG’s investment approach may fail to produce the intended results. If our
perception of the performance of a specific asset class or underlying fund is not realized in the
expected time frame, the overall performance of client’s portfolio may suffer.
Equity Risk. Equity securities tend to be more volatile than other investment choices. The value
of an individual mutual fund or ETF can be more volatile than the market as a whole. This
volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are
subject to additional risks. Smaller companies may experience greater volatility, higher failure
rates, more limited markets, product lines, financial resources, and less management experience
than larger companies. Smaller companies may also have a lower trading volume, which may
disproportionately affect their market price, tending to make them fall more in response to
selling pressure than is the case with larger companies.
Fixed Income Risk. The issuer of a fixed income security may not be able to make interest and
principal payments when due. Generally, the lower the credit rating of a security, the greater the
risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower
rating, the value of the debt security will decline because investors will demand a higher rate of
return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. A
nominal interest rate is the sum of a real interest rate and an expected inflation rate.
Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and may
be affected by adverse political, legislative and tax changes, as well as by financial developments
that affect the municipal issuers. Because many municipal obligations are issued to finance
similar projects by municipalities (e.g., housing, healthcare, water and sewer projects, etc.),
conditions in the sector related to the project can affect the overall municipal market. Payment
of municipal obligations may depend on an issuer’s general unrestricted revenues, revenue
generated by a specific project, the operator of the project, or government appropriation or aid.
There is a greater risk if investors can look only to the revenue generated by the project. In
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addition, municipal bonds generally are traded in the “over-the-counter” market among dealers
and other large institutional investors. From time to time, liquidity in the municipal bond market
(the ability to buy and sell bonds readily) may be reduced in response to overall economic
conditions and credit tightening.
Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the
client indirectly bears its proportionate share of any fees and expenses payable directly by those
funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In
addition, the client’s overall portfolio may be affected by losses of an underlying fund and the
level of risk arising from the investment practices of an underlying fund (such as the use of
derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a
market price that is above or below their net asset value; (ii) the ETF may employ an investment
strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the
listing exchange’s officials deem such action appropriate, the shares are de-listed from the
exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases
in stock prices) halts stock trading generally. TFG has no control over the risks taken by the
underlying funds.
Voting Client Securities
TFG does not vote proxies on behalf of Client advisory accounts. At the Client’s request, TFG
may offer the Client advice regarding corporate actions and the exercise of proxy voting rights. If
the Client owns shares of common stock or mutual funds, the Client is responsible for exercising
the right to vote as a shareholder.
In most cases, the Client will receive proxy materials directly from the account custodian.
However, in the event TFG receives any written or electronic proxy materials, we would forward
them directly to the Client by mail, unless the Client has authorized our firm to contact you by
electronic mail, in which case, TFG would forward any electronic solicitation to vote proxies.
Form ADV, Part 2A Appendix 1, Item 7
Client Information Provided to Portfolio Managers
TFG may directly provide the portfolio management services for the Wrap Fee Program
accounts. As such, TFG receives all information provided by the Client through a formal Needs
Analysis and consultation with the Client. Advice is provided through consultation with the
client and may include: determination of financial objectives, identification of financial
problems, cash flow management, tax planning, insurance review, investment management,
education funding, retirement planning, and estate planning.
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Form ADV, Part 2A Appendix 1, Item 8
Client Contact With Portfolio Managers
There are no restrictions placed on TFG’s clients’ ability to contact and consult with their
portfolio manager(s).
Form ADV, Part 2A Appendix 1, Item 9
Additional Information
Disciplinary Information
TFG or its Principal Executive Officers have not had any reportable disclosable events in the
past ten years.
Other Financial Industry Activities and Affiliations
Douglas Ray Tucker, Jr. is a licensed insurance agent. From time to time, he will offer clients
advice or products from those activities. Clients should be aware that these services pay a
commission and involve a conflict of interest, as commissionable products can conflict with the
fiduciary duties of a registered investment adviser. Tucker Financial Group always acts in the
best interest of the client; including the sale of commissionable products to advisory clients.
Clients are in no way required to implement the plan through any representative of Tucker
Financial Group in their capacity as an insurance agent.
The IARs of TFG are not currently registered with any broker dealer.
Neither TFG nor its representatives are registered as a Futures Commission Merchant,
Commodity Pool Operator, or a Commodity Trading Advisor.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
TFG’s Code of Ethics includes guidelines for professional standards of conduct for our
Associated Persons. Our goal is to protect client interests at all times and to demonstrate our
commitment to fiduciary duties of honesty, good faith, and fair dealing. All of TFG’s Associated
Persons are expected to strictly adhere to these guidelines. Persons associated with TFG are also
required to report any violations to the Code of Ethics. Additionally, the firm maintains and
enforces written policies reasonably designed to prevent the misuse or dissemination of material,
non-public information about our clients or client accounts by persons associated with our firm.
TFG may buy or sell securities for itself that we also recommend to clients. In addition, the
individual IARs may buy or sell the same securities for their personal and family accounts that
are bought and sold for your account(s).
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TFG or its IARs may have an interest or position in a certain security, which may also be
recommended to the client. As these situations present a conflict of interest, TFG has established
the following restrictions in order to ensure its fiduciary responsibilities:
1.
2.
3.
4.
A director, officer or employee of the advisor shall not buy or sell a security for their
personal portfolio(s) where their decision is substantially derived, in whole or part, by
reason of his or her employment, unless the information is also available to the investing
public. No owner/employee of TFG shall prefer their own interest to that of the client.
The advisor maintains a list of all securities held by the company and all directors,
officers, and employees. These holdings are reviewed on a quarterly basis by the
principal of the firm.
The advisor requires that all employees must act in accordance with all applicable
Federal and State regulations governing registered investment advisors.
The advisor will monitor any blocking of personal trades with those of clients to ensure
that clients are not at a disadvantage.
TFG’s Code of Ethics is available to you upon request. You may obtain a copy of our Code of
Ethics by contacting Douglas Ray Tucker, Jr. at (334) 277-0500.
TFG does not recommend or select other investment advisors to our clients for which we receive
compensation, directly or indirectly, from those advisors, nor do we have business relationships
with any other investment advisors.
Review of Accounts
Client accounts are reviewed at least quarterly by Douglas Ray Tucker, Jr., the Principal
Executive Officer of the firm. Client accounts are reviewed with regard to their investment
policies and risk tolerance levels. All accounts at TFG are reviewed by this reviewer.
Reviews may also be triggered by material market, economic or political events, or by changes
in client's financial situations (such as retirement, termination of employment, physical move, or
inheritance).
Each client will receive at least quarterly a written report that details the clients’ account which
may come from the custodian.
Client Referrals and Other Compensation
TFG advertises their investment advisory services on the website of The Lampo Group, LLC
d/b/a Ramsey Solutions™ (“RS”), which operates a program known as SmartVestor™. As the
Securities and Exchange Commission deems RS to be a promoter within the meaning of Rule
206(4)-1 under the Investment Advisers Act of 1940, TFG makes the following disclosure: RS is
neither a client of, nor investor in, TFG. TFG believes there are no conflicts of interest arising
from RS serving in the capacity of promoter since RS’ function is that of a lead generator. RS
will not derive any involvement with TFG clients from this business arrangement.
SmartVestor™ is an advertising service for investing professionals. When a consumer provides
contact information through the SmartVestor™ website, the program introduces the consumer to
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up to five (5) investing professionals (“Pros”) in their geographic area. It is up to the consumer to
interview the Pros and decide whether to directly retain them. As a SmartVestor™ Pro, TFG
pays RS a flat monthly membership and advertising fee to advertise their services in the
SmartVestor™ Program. In return, TFG receives contact information for prospective investment
advisory clients. Consumers entering a zip code corresponding to TFG’s advertising markets can
view their profile, and other Pros in the same markets, on the SmartVestor™ website. The
advertising fee is based upon criteria including market size (small, medium, large or premium)
and historic volume of web traffic to RS’ SmartVestor™ website. The fees paid by TFG are
irrespective of whether someone becomes a client, and the fees are not passed on to the client.
The fees paid are not based upon the number of leads, contacts, or referrals which TFG may
receive from RS or the SmartVestor™ website. TFG do not pay to or share with RS or
SmartVestor™ any portion of the investment advisory fees a client is charged. Neither RS nor its
affiliates are engaged in providing investment advice. RS does not receive, control, access or
monitor client funds, accounts, or portfolios of TFG. Any services rendered by TFG are solely
their services and not those of RS or SmartVestor™.
Our firm may engage in promoter arrangements for client referrals. These individual promoters
offer our services to the public. The Firm pays a referral fee to the promoter based on a portion
of the management fees charged by the Firm and memorialized in a written agreement
(“Promoter Agreement”). In all cases, the Firm will comply with the cash solicitation rules
established by the SEC, state regulators and the client disclosure requirements. If a referred
prospective client enters into an investment advisory agreement with the Firm, a referral fee is
paid to the referring party. The referral relationship will not result in clients being charged any
fees over and above the normal advisory fees charged for the advisory services provided. The
Firm will pay the promoter their share of the total fee. The Promoter Agreement requires that the
promoter be appropriately registered under federal and state securities laws where applicable.
Clients receive all related agreements and disclosures prior to or at the time of entering into an
Investment Advisory Agreement with the Firm.
Financial Information
TFG is not required to provide financial information to our clients because we do not require or
solicit the prepayment of more than $1,200 six or more months in advance.
Form ADV, Part 2A Appendix 1, Item 10
Requirements for State-Registered Advisers
This section is not applicable, as the firm is registered with the SEC.
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