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ADV PART 2A FIRM BROCHURE
For Clients and Prospective Clients
March 18, 2026
6025 Brookvale Lane, Suite 160
Knoxville, TN 37919
(865) 226-9982
This disclosure brochure provides information about the qualifications and business practices of TVAMP
LLC (also referred to as we, us and TVAMP throughout this disclosure brochure). If you have any
questions about the contents of this disclosure brochure, please contact Jeff B. Foster at (865) 226-
9982 or jeff.foster@tvamp.com. The information in this disclosure brochure has not been approved or
verified by the United States Securities and Exchange Commission or by any state securities authority.
Additional information about TVAMP is also available on the SEC’s website at www.adviserinfo.sec.gov.
You can view our firm’s information on this website by searching for TVAMP, LLC or our firm’s CRD
number 160321.
Registration as an investment advisor does not imply a certain level of skill or training.
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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Item 2 – Material Changes
TVAMP encourages all current and prospective clients to read this Disclosure Brochure and discuss any
questions you have with the Advisor. Since our last ADV amendment filed in March 2025, TVAMP has
made the following changes:
Accounting Liaison Services Offering
TVAMP has added Accounting Liaison Services as an optional service available to clients receiving Asset
Management Services. These services may include coordinating with TVAMP Tax Planning LLC for tax return
preparation and filing, compiling and transmitting tax-related information, participating in meetings with the
client and tax preparer, assisting with implementation of tax strategies, and reviewing completed tax returns.
Clients selecting this service must sign an addendum to the Asset Management Agreement outlining the
scope of services. TVAMP does not provide specific tax advice and engages TVAMP Tax Planning LLC to
provide tax services as needed.
Retirement Plan Advisory Services (ERISA 3(21) and 3(38))
TVAMP has added Retirement Plan Advisory Services for employer-sponsored retirement plans. The firm
offers both non-discretionary ERISA §3(21) fiduciary services and discretionary ERISA §3(38) investment
management services pursuant to written agreements with plan sponsors.
Methods of Analysis, Investment Strategies and Risk of Loss
TVAMP revised Item 8 to better align the disclosure with the firm’s investment practices and services. The
section was updated to clarify the methods of analysis used, describe the types of securities and investment
strategies that may be recommended, and expand the discussion of risks associated with those strategies.
Risk disclosures were also updated to address retirement plan advisory services provided under ERISA and
investments that may provide indirect exposure to digital assets.
Client Referral Arrangement
TVAMP has entered into a referral agreement with Zoe Financial, Inc., an SEC-registered investment adviser.
Under this arrangement, Zoe refers prospective clients to TVAMP, and TVAMP pays Zoe a portion of the
advisory fees received from referred clients. This referral compensation is paid by TVAMP and does not
increase the advisory fees paid by clients.
Educational and Media Activities of Investment Adviser Representatives
TVAMP has added disclosure regarding certain educational and media activities of investment adviser
representatives. Certain investment adviser representatives may be employed as a university professor
teaching personal finance courses. This role is separate from TVAMP’s advisory services. The university
does not endorse TVAMP, does not compensate TVAMP for advisory services, and does not receive referral
compensation.
Updates to Fees and Compensation Disclosure
TVAMP has revised Item 5 – Fees and Compensation to improve clarity and transparency regarding the firm’s
advisory fee arrangements and related conflicts of interest. These updates include simplifying the
presentation of the firm’s asset management fee schedule, clarifying how advisory fees are calculated and
billed, and consolidating disclosures regarding investment-related expenses into a single “Other Fees and
Expenses” section.
TVAMP has also enhanced its disclosures regarding compensation and conflicts of interest, including
clarifying that compensation received by the firm may vary depending on the advisory program selected,
expanding disclosure regarding 12b-1 fees and the indirect financial benefit to investment adviser
representatives, and strengthening disclosure regarding transaction cost-related conflicts and other incentives
associated with its relationship with LPL Financial.
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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.
Social Media and Video-Sharing Platform Activities
TVAMP has also added disclosure regarding the use of social media and video-sharing platforms by
supervised persons. Representatives are compensated in part based on advisory fees generated from client
relationships and may receive compensation for introducing new client relationships, creating a financial
incentive to encourage prospective clients to engage TVAMP’s services.
Digital Asset Exposure Through Exchange-Traded Funds
TVAMP has also added disclosure regarding limited exposure to digital assets through publicly traded ETFs
that track bitcoin or similar digital-asset benchmarks. These investments involve heightened volatility,
regulatory uncertainty, liquidity risks, and tracking error risk. TVAMP does not facilitate direct cryptocurrency
purchases or custody.
We will ensure that you receive a summary of material changes, if any, to this and subsequent disclosure
brochures within 120 days after our fiscal year ends. Our fiscal year ends on December 31 so you will
receive the summary of material changes, if any, no later than April 30 each year. At that time, we will
also offer a copy of the most current disclosure brochure. We may also provide other ongoing disclosure
information about material changes as necessary.
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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Item 3 – Table of Contents
ADV PART 2A FIRM BROCHURE .........................................................................................................................1
Item 2 – Material Changes .....................................................................................................................................2
Item 3 – Table of Contents .....................................................................................................................................4
Item 4 – Advisory Business .....................................................................................................................................5
Item 5 – Fees and Compensation ........................................................................................................................ 15
Item 6 – Performance-Based Fees and Side-By-Side Management.................................................................... 19
Item 7 – Types of Clients ..................................................................................................................................... 19
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................... 19
Item 9 – Disciplinary Information .......................................................................................................................... 22
Item 10 – Other Financial Industry Activities and Affiliations ................................................................................ 22
Item 12 – Brokerage Practices ............................................................................................................................. 25
Item 13 – Review of Accounts ............................................................................................................................. 29
Item 14 – Client Referrals and Other Compensation ........................................................................................... 30
Item 15 – Custody ................................................................................................................................................ 32
Item 16 – Investment Discretion ........................................................................................................................... 33
Item 17 – Voting Client Securities ........................................................................................................................ 33
Item 18 – Financial Information ............................................................................................................................ 34
TVAMP Customer Privacy Policy Notice ............................................................................................................. 35
Office Locations ................................................................................................................................................... 37
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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Item 4 – Advisory Business
TVAMP is an investment advisor registered with the U.S. Securities and Exchange Commission and is a
limited liability company (LLC) formed under the laws of the State of Tennessee.
• Luke A. Bowes is a Managing Member of TVAMP.
• Perry L. Chesney, Jr. is a Managing Member of TVAMP.
Jeffrey B. Foster, Charles J. Sweat, and Scott B. Fisher are Members of TVAMP.
•
Introduction
The investment advisory services of TVAMP are provided to you through an appropriately licensed and
qualified individual who is an investment adviser representative of TVAMP (referred to as your investment
adviser representative throughout this brochure).
Your investment adviser representative may either be an employee or independent contractor of TVAMP.
Your investment adviser representative is limited to providing the services and charging investment
advisory fees in accordance with the descriptions detailed in this brochure. However, the exact services
you will receive and the fees you will be charged are dependent upon your investment adviser
representative and your geographic location.
Description of Advisory Services
The following are descriptions of the primary services of TVAMP. Please understand that a written
agreement, which details the exact terms of the service, must be signed by you and TVAMP before we
can provide you with the services described below.
Asset Management Services – TVAMP offers asset management services, which involves TVAMP
providing you with continuous and on-going supervision over your specified accounts.
You must appoint our firm as your investment adviser of record on specified accounts (collectively, the
“Account”). The Account consists only of separate account(s) held by qualified custodian(s) under your
name. The qualified custodians maintain physical custody of all funds and securities of the Account, and
you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy
voting and receive transaction confirmations) of the Account.
The Account is managed by us based on your financial situation, investment objectives and risk
tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting or
holding securities, cash or other investments in the Account.
We will need to obtain certain information from you to determine your financial situation and investment
objectives. Accounts are therefore managed on the basis of your individual financial situation and
investment objectives. We encourage clients, at least quarterly, to notify us whether your financial
situation or investment objectives have changed, or if you want to impose and/or modify any reasonable
restrictions on the management of your accounts. At least annually, we contact individual clients to
determine whether their financial situation or investment objectives have changed, or if the client wants to
impose and/or modify any reasonable restrictions on the management of accounts managed. We are
always reasonably available to consult with individual clients relative to the status of their accounts. You
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have the ability to impose reasonable restrictions on the management of your accounts, including the
ability to instruct us not to purchase certain securities.
It is important that you understand that we manage investments for other clients and may give them
advice or take actions for them or for our personal accounts that is different from the advice we provide to
you or actions we take for you. We are not obligated to buy, sell or recommend to you any security or
other investment that we may buy, sell or recommend for any other clients or for our own accounts.
Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We
strive to allocate investment opportunities believed appropriate for your account(s) and other accounts
advised by our firm among such accounts equitably and consistent with the best interests of all accounts
involved. However, there can be no assurance that a particular investment opportunity that comes to our
attention will be allocated in any particular manner. If we obtain material, non-public information about a
security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose
the information to any client or use it for any client’s benefit.
Retirement Plan Rollover Recommendations – TVAMP does not recommend rollovers to our clients or
prospects. The firm’s activities will be strictly limited to educating clients and prospects as to their
options.
Should you decide to engage TVAMP to provide investment advice to you regarding your retirement plan
account or individual retirement account, we become fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are
laws governing retirement accounts. The way we make money creates some conflicts with your interests,
so we operate under a special rule that requires us to act in your best interest and not put our interest
ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management and,
in turn, our advisory fees.
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Financial Planning & Consulting Services – TVAMP offer financial planning services that can
involve preparing a written financial plan covering specific or multiple topics. We can provide full written
financial plans, which typically address the following topics: Investment Planning, Retirement Planning,
Insurance Planning, Education Planning, Portfolios Review, and Asset Allocation. Under this program,
the role of your investment adviser representative as a financial planner is to find ways to help you
understand your overall financial situation and help you set financial objectives. We also provide modular
financial plans which only cover those specific areas of concern mutually agreed upon by you and us. A
modular written financial plan is limited or segmented and does not involve the creation of a full written
financial plan.
You should be aware that other important issues may not be taken into consideration when your
investment adviser representative develops his or her analysis and recommendations under a modular
written financial plan. Written financial plans prepared by us under this Agreement do not include specific
recommendations of individual securities.
We also offer consultations in order to discuss financial planning issues when you do not need a written
financial plan. We offer a one-time consultation, which covers mutually agreed upon areas of concern
related to investments or financial planning. We also offer “as-needed” consultations, which are limited
to consultations in response to a particular investment or financial planning issue raised or request made
by you. Under an “as-needed” consultation, it will be incumbent upon you to identify those particular
issues for which you are seeking our advice or consultation on.
In addition to these services, we offer ongoing advisement consultations to participants in retirement
plans (401(k) plans, profit sharing plans, etc.). When providing these services, we review your financial
situation, goals and objectives as well as the investment options available in the retirement plan. We will
review your retirement plan account at semi-annually intervals and will make such recommendations from
the list of available investment options in your retirement plan account as are deemed appropriate and
consistent with your stated investment objectives and risk tolerance. These services do not constitute
asset management services for your retirement plan account; we do not have investment discretion or
trading authority over your retirement plan account. You determine whether or not to implement our
advice. The implementation of any trades in your retirement plan account is your responsibility.
for determining whether
to
implement our
Our financial planning and consulting services do not involve implementing any transaction on your behalf
or the active and ongoing monitoring or management of your investments or accounts. You have the sole
responsibility
financial planning and consulting
recommendations. To the extent that you would like to implement any of our investment recommendations
through TVAMP or retain TVAMP to actively monitor your investments, you must execute a separate written
agreement with TVAMP for our asset management services.
Estate Planning
TVAMP may utilize third-party software platforms and service providers to assist clients with estate
planning organization, document preparation support, and coordination with estate planning
professionals. TVAMP may gather and organize relevant documents and information to assist clients
with the creation or updating of estate planning materials.
Fees associated with estate planning services are separate from financial planning or advisory fees and
are disclosed in Item 5 – Fees and Compensation.
Referral of Third-Party Money Managers
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TVAMP offers advisory services by referring clients to a third-party money manager offering asset
management and other investment advisory services. The third-party managers are responsible for
continuously monitoring client accounts and making trades in client accounts when necessary. As a
result of the referral, we are paid a portion of the fee charged and collected by the third-party money
managers in the form of solicitor fees. Each solicitation arrangement is performed pursuant to a written
solicitation agreement and is in compliance with SEC Rule 206(4)-1 and applicable state securities rules
and regulations.
Under this program, we assist you with identifying your risk tolerance and investment objectives. We
recommend outside money managers in relation to your stated investment objectives and risk tolerance,
and you may select a recommended third-party money manager or model portfolio based upon your
needs. You must enter into an agreement directly with the third-party money manager who provides your
designated account with asset management services.
We are available to answer questions that you may have regarding your account and act as the
communication conduit between you and the third-party money manager. The third-party money
manager may take discretionary authority to determine the securities to be purchased and sold for you.
We do not have any trading authority with respect to your designated account managed by the outside
money manager.
Although we review the performance of numerous third-party investment advisor firms, we enter into only
a select number of relationships with third-party investment advisor firms that have agreed to pay us a
portion of the overall fee charged to our clients. Therefore, TVAMP has a conflict of interest in that it will
only recommend third-party investment advisors that will agree to compensate us for referrals of our
clients.
Clients are advised that there may be other third-party managed programs, not recommended by our firm,
that are suitable for the client and that may be more or less costly than arrangements recommended by
our firm. No guarantees can be made that a client’s financial goals or objectives will be achieved by a
third-party investment advisor recommended by our firm. Further, no guarantees of performance can
ever be offered by our firm (please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk
of Loss for more details).
LPL Financial Sponsored Advisory Programs
TVAMP may provide advisory services through certain programs sponsored by LPL Financial LLC (LPL),
a registered investment advisor and broker-dealer. Below is a brief description of each LPL advisory
program available to TVAMP. For more information regarding the LPL programs, including more
information on the advisory services and fees that apply, the types of investments available in the programs
and the potential conflicts of interest presented by the programs please see the program account packet
(which includes the account agreement and LPL Form ADV program brochure) and the Form ADV, Part 2A
of LPL or the applicable program.
Manager Access Select Program
Manager Access Select provides clients access to the investment advisory services of professional portfolio
management firms for the individual management of client accounts. The advisor will assist the client in
identifying a third-party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made
available by LPL. The Portfolio Manager manages a client’s assets on a discretionary basis. The advisor
will provide initial and ongoing assistance regarding the Portfolio Manager selection process.
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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A minimum account value of $100,000 is most commonly required for Manager Access Select, however, in
certain instances, the minimum account size may be as little as $25,000 and as high as $250,000.
Optimum Market Portfolios
We have entered into an arrangement with LPL to provide services through the Optimum Market Portfolios
Program (“OMP”), a wrap-fee program sponsored by LPL. If you contract for this service, you must establish
a brokerage account through LPL which serves as the broker/dealer and qualified custodian. OMP offers
clients the ability to participate in a professionally managed asset allocation program using OMP Funds
Class I shares.
We obtain your necessary financial data and assist you in determining the suitability of OMP and in setting
an appropriate investment objective. We assist you with opening an account and determining an investment
portfolio. Once the program minimum has been reached and a portfolio selected, LPL purchases OMP
funds in amounts appropriate for the portfolio selected. LPL is responsible for rebalancing the account on
the frequency selected jointly by you and us. There are several OMP funds that may be purchased within
an OMP account. LPL follows a strategic asset allocation investment style in constructing portfolios for OMP
clients. Asset allocation methodology is implemented by combining investments representing various asset
classes that reflect differently to varying market conditions. Thus, if one asset class reacts negatively to
certain market events, the potential exists for another asset class to react positively. However, there is no
guarantee that the use of an asset allocation strategy will produce favorable results. We are responsible for
providing you with information about the investment strategy and the portfolios selected for you.
LPL will directly provide you with quarterly account statements (monthly when activity occurs in the
account), confirmations and performance reports.
Model Wealth Portfolios
We have an arrangement with LPL to provide services through the Model Wealth Portfolios (“MWP”)
program, a wrap-fee program sponsored by LPL. If you contract for this service, you must establish a
brokerage account through LPL which serves as the broker/dealer and qualified custodian. MWP offers
clients a professionally managed mutual fund asset allocation program in which LPL, in its capacity as an
investment advisor, directs and manages specified client assets. A minimum account value of $25,000 is
required for MWP.
We obtain your necessary financial data and assist you in determining the suitability of MWP and in
setting an appropriate investment objective. We assist you in opening an account and determining an
investment portfolio designed by LPL’s Research Department. LPL’s Research Department is
responsible for selecting the mutual funds within a portfolio and for making changes to the mutual funds
selected. In certain cases, a portfolio may consist only of mutual funds within the same fund family. In
such a portfolio, LPL’s Research Department will select only those mutual funds within the fund family.
You must grant TVAMP discretionary authority to select the portfolios suitable for you and must grant LPL
discretionary authority to select investments held within portfolios and rebalance positions within the
portfolios.
LPL follows a dynamic asset allocation investment style in constructing portfolios for MWP clients. Asset
allocation methodology is implemented by combining investments representing various asset classes that
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respond differently to varying market conditions. Thus, if one asset class reacts negatively to certain
market events, the potential exists for another asset class to react positively. However, there is no
guarantee that the use of an asset allocation strategy will produce favorable results. We are responsible
for providing you with information about the investment strategy and the portfolios selected for you.
You receive quarterly account statements (monthly when activity occurs in the account), confirmations,
and performance reports directly from LPL.
Variable Sub-Account Management Services – Under our sub-account management services,
TVAMP manages your variable annuity contract by selecting, monitoring and exchanging as necessary
between sub-accounts available from the insurance company issuing the variable annuity contract.
Under this program, we work with you to understand your financial goals, investment objectives, time
horizon, and risk tolerance. . You will have the opportunity to list on your investment advisory agreement
with our firm any reasonable restrictions on the sub-accounts that may be utilized by TVAMP. You will be
responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment
objective and whether you wish to impose or modify existing investment restrictions; however, we will
contact you at least annually to discuss any changes or updates regarding your financial situation, risk
tolerance or investment objectives.
Once you have provided us with the necessary information and made the appropriate authorizations,
TVAMP utilizes trading authority to place the transactions as directed by you. TVAMP may utilize signal
providers for guidance regarding investment strategies, asset allocations and timing of exchanges.
TVAMP will monitor your sub-accounts and exchange sub-accounts as necessary and in accordance with
your investment objective and risk tolerance.
Newsletters
TVAMP occasionally prepares general, educational, and informational newsletters. Newsletters are
always offered on an impersonal basis and do not focus on the needs of a specific individual.
Seminars
TVAMP may occasionally provide seminars in areas such as financial planning, retirement planning,
estate planning, college planning and charitable planning. Seminars are always offered on an impersonal
basis and do not focus on the individual needs of participants.
Workshops
TVAMP offers educational, informative and motivational workshops to the public as well as associations,
family foundations and employers. Workshops are always offered on an impersonal basis and do not
focus on the individual needs of the participants.
Non-Discretionary Investment Consulting
TVAMP offers limited, non-discretionary investment consulting services to Clients who do not seek
ongoing portfolio management or other investment advisory services referenced in this brochure. These
services are designed for Clients who wish to retain full control over their investment decisions and are
offered advice solely in response to specific Client-initiated requests. TVAMP reserves the right to waive
applicable minimums and fees at its sole discretion. If a client later desires ongoing investment advisory
services or portfolio management, a separate written agreement under TVAMP’s standard Investment
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Advisory Services Agreement or Financial Plan Agreement is required.
Accounting Liaison Services
If selected by the client, TVAMP will provide Accounting Liaison Services. These services will only be
provided to clients who have hired TVAMP to provide Asset Management Services. These services may
include:
• Selection of TVAMP Tax Planning LLC (“TVAMP Tax”) for preparation and filing of client
tax returns;
• Compiling relevant information to send to TVAMP Tax;
• Meeting with TVAMP Tax and the client as needed to discuss the client situation and
relevant specific information;
Implementation of tax strategies; and
•
• Review of tax returns prepared by TVAMP Tax.
All clients who select TVAMP to provide Accounting Liaison Services will be required to sign an
Addendum to the TVAMP Asset Management Agreement setting forth the exact accounting liaison
services to be provided.
TVAMP is not licensed to provide specific tax advice and hires TVAMP Tax as needed to provide tax
services for TVAMP clients. For more information on TVAMP Tax, please see Item 10 of this Brochure.
Educational Activities and Social Media
Certain investment adviser representatives of TVAMP may engage in educational activities outside of
their role with the firm. For example, an investment adviser representative may be employed as a
university professor and teach courses related to personal finance or other financial topics. Such
employment is separate from the advisory services provided by TVAMP.
TVAMP does not compensate any university or educational institution for referrals, and the university
does not endorse or sponsor TVAMP’s advisory services. Any advisory relationship is established solely
through a separate written agreement between the client and TVAMP.
From time to time, TVAMP may advertise in university publications or communicate with individuals who
independently express interest in learning more about the firm’s services. Educational presentations,
workshops, or similar events are provided for general informational purposes only and do not constitute
individualized investment advice.
In addition, certain supervised persons of TVAMP may maintain personal websites, blogs, podcasts, or
social media channels (including video-sharing platforms) that provide general educational content
related to investing, financial planning, or retirement planning. TVAMP may review and republish such
content through the firm’s own marketing channels. All such communications are intended for general
informational purposes and are not tailored to the needs of any specific individual.
Because investment adviser representatives are compensated based in part on advisory fees generated
from client relationships, they have a financial incentive to encourage prospective clients, including
individuals who learn about TVAMP through educational activities or social media, to engage the firm’s
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advisory services. This presents a conflict of interest. TVAMP addresses this conflict through its fiduciary
duty to act in the best interests of clients and through supervisory oversight of marketing
communications.
Retirement Plan Advisory Services (ERISA 3(21) and 3(38))
TVAMP provides advisory services to employer-sponsored retirement plans, including both non-
discretionary ERISA §3(21) fiduciary services and discretionary ERISA §3(38) investment management
services. These services are offered pursuant to written agreements entered into with the plan sponsor.
The scope of services varies by engagement and is described in the applicable agreement.
Under a 3(21) non-discretionary engagement, TVAMP assists the plan sponsor with the development
and review of the plan’s investment policy statement (“IPS”), provides recommendations regarding
investment options, assists with monitoring investment performance, and provides general investment
education to plan participants. The plan sponsor retains full authority and responsibility for selecting,
removing, or replacing investment options.
Under a 3(38) discretionary engagement, TVAMP has full discretionary authority to select, monitor, and
replace the plan’s investment options in accordance with the IPS. TVAMP may also direct the plan’s
recordkeeper to rebalance model portfolios or investment option allocations. The plan sponsor retains
responsibility for ongoing oversight of TVAMP and compliance with ERISA Section 404(c), if applicable.
In both programs, TVAMP may also provide non-fiduciary services, such as general investment
education and group enrollment meetings, which do not involve individualized advice to plan participants.
TVAMP does not provide legal, tax, or actuarial advice and does not act as the plan administrator or
trustee.
Limits Advice to Certain Types of Investments
Although we generally provide advice on Mutual Funds and Exchange Traded Funds, we reserve the
right to offer advice on any investment product that may be suitable for each client’s specific
circumstances, needs, goals and objectives.
TVAMP provides investment advice on the following types of investments:
Interests in Partnerships Investing in Real Estate
Interests in Partnerships Investing in Oil and Gas Interests
• Mutual Funds
• Exchange Traded Funds (ETFs)
• Exchange-listed Securities
• Securities Traded Over-the-Counter
• Foreign Issues
• Warrants
• Corporate Debt Securities
• Commercial Paper
• Certificates of Deposit
• Municipal Securities
• Variable Annuities that have been approved for inclusion in the LPL Platform
• US Government Securities
• Options Contracts on Securities
•
•
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Different fund categories have different risk characteristics and investors should not compare different
categories. For example, a bond fund and a stock fund that both have below average risk still have
different risk/return potential (stock funds traditionally have higher risk/return potential). Risks are based
on the investments held in the fund. For example, a bond fund faces interest rate risk and income risk,
and income is affected by the change in interest rates. A sector fund (investing in a single industry) is at
risk that its price will decline due to industry developments. The following are risks to consider when
investing in mutual funds:
• Call Risk: A bond issuer may redeem high-yield bonds before maturity date due to falling
interest rates.
• Default Risk: A bond issuer may fail to repay interest and principal.
•
Income Risk: Dividends in a fixed income fund may decline due to falling interest rates.
• Geology Risk: Political events, natural disasters or financial problems may weaken a country
•
•
or state’s economy and cause investments to decline.
Industry Risk: Stocks in a single industry may decline due to developments in that industry.
Inflation Risk: Increases in the cost of living can reduce or eliminate a fund’s actual returns
when adjusted for inflation.
• Manager Risk: A manager may not execute the fund’s investment strategy in a timely or
effective manner.
When providing asset management services, TVAMP typically constructs each client’s account holdings
using Exchange Traded Funds and Mutual Funds to build diversified portfolios. We may modify our
investment strategy to accommodate special situations such as low basis stock, stock options, legacy
holdings, inheritances, closely held businesses, collectibles, or special tax situations.
You have the ability to place reasonable restrictions on the types of investments that may be purchased
in your account.
(Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more
information.)
Participation in Wrap Fee Programs
TVAMP offers services through both wrap-fee programs and non-wrap fee programs. A wrap fee
program is defined as any advisory program under which a specified fee or fees not based directly upon
transactions in a client’s account is charged for investment advisory services (which may include portfolio
management or advice concerning the selection of other investment advisers) and the execution of client
transactions. Whenever a fee is charged to a client for services described in this brochure (whether wrap
fee or non-wrap fee), we will receive all or a portion of the fee charged.
WRAP Fee Program Disclosure
As representative of LPL Financial, LLC, the investment advisor representatives of TVAMP have the
ability to offer WRAP account services conducted though the LPL SWM-ADV program. Although clients
do not pay a transaction charge for transactions in a SWM-ADV account, clients should be aware that
TVAMP pays LPL transaction charges for those transactions. The transaction charges paid by TVAMP
vary based on the type of transaction (e.g., mutual fund, equity or ETF) and for mutual funds based on
whether or not the mutual fund pays 12b-1 fees and/or recordkeeping fees to LPL. Transaction charges
paid by the Advisor for equities are $7 and ETFs are $0-$9. For mutual funds, the transaction charges
range from $0 to $26.50. Because TVAMP pays the transaction charges in SWM-ADV accounts, there is
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a conflict of interest in cases where the mutual fund is offered at both $0 and $26.50. Clients should
understand that the cost to Advisor of transaction charges may be a factor that TVAMP considers when
deciding which securities to select and how frequently to place transactions in a SWM-ADV account.
In many instances, LPL makes available mutual funds in a SWM-ADV account that offer various classes
of shares, including shares designated as Class A Shares and shares designed for advisory programs,
which can be titled, for example, as “Class I,” “institutional,” “investor,” “retail,” “service,” “administrative”
or “platform” share classes (“Platform Shares”). The Platform Share class offered for a particular mutual
fund in SWM-ADV in many cases will not be the least expensive share class that the mutual fund makes
available and was selected by LPL in certain cases because the share class pays LPL compensation for
the administrative and recordkeeping services LPL provides to the mutual fund. Client should understand
that another financial services firm may offer the same mutual fund at a lower overall cost to the investor
than is available through SWM-ADV. In other instances, a mutual fund may offer only Class A Shares, but
another similar mutual fund may be available that offers Platform Shares. Class A Shares typically pay
LPL a 12b-1 fee for providing shareholder services, distribution, and marketing expenses (“brokerage-
related services”) to the mutual funds. Platform Shares generally are not subject to 12b-1 fees. As a result
of the different expenses of the mutual fund share classes, it is generally more expensive for a client to
own Class A Shares than Platform Shares. An investor in Platform Shares will pay lower fees over time
and keep more of his or her investment returns than an investor who holds Class A Shares of the same
fund. Other financial services firms may offer the same mutual fund at a lower overall cost to the investor
than is available through the LPL Programs.
TVAMP has a financial incentive to recommend Class A Shares in cases where both Class A and
Platform Shares are available. This is a conflict of interest which might incline TVAMP, consciously or
unconsciously, to render advice that is not disinteresting. Although the client will not be charged a
transaction charge for transactions, Advisor pays LPL a per transaction charge for mutual fund purchases
and sales in the account. TVAMP generally does not pay transaction charges for Class A Share mutual
fund transactions accounts but generally does pay transaction charges for Platform Share mutual fund
transactions. The cost to TVAMP of transaction charges generally may be a factor Advisor considers
when deciding which securities to select and whether or not to place transactions in the account.
Tailor Advisory Services to Individual Needs of Clients
TVAMP’s services are always provided based on your individual needs. This means, for example, that
you are given the ability to impose restrictions on the accounts we manage for you, including specific
investment selections and sectors. We work with you on a one-on-one basis through interviews and
questionnaires to determine your investment objectives and suitability information.
Our financial planning and consulting services are always provided based on your individual needs. We
work with you on a one-on-one basis through interviews and questionnaires to determine your investment
objectives and suitability information.
However, we will not enter into an investment advisor relationship with a prospective client whose
investment objectives may be considered incompatible with our investment philosophy or strategies or
where the prospective client seeks to impose unduly restrictive investment guidelines.
When managing client accounts through our firm’s Asset Management Services program, we may
manage a client’s account in accordance with one or more investment models. When client accounts are
managed using models, investment selections are based on the underlying model and we do not develop
customized (or individualized) portfolio holdings for each client. However, the determination to use a
particular model or models is always based on each client’s individual investment goals, objectives and
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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mandates.
Client Assets Managed by TVAMP
The amount of client’s assets managed by us totaled $1,185,099,837as of December 31, 2025
$1,174,287,250 is managed on a discretionary basis and $10,812,581 is managed on a non-discretionary
basis.
Item 5 – Fees and Compensation
TVAMP provides ongoing investment management services for client accounts. These services include
providing continuous investment advice, portfolio management, and monitoring of client accounts based
on the client’s financial circumstances, investment objectives, and risk tolerance.
Fees for asset management services are generally based on a percentage of assets under management
and are billed quarterly in advance based on the value of the account as of the last business day of the
prior calendar quarter. Fees are prorated for accounts opened or terminated during a billing period.
For accounts custodied at LPL Financial, advisory fee calculations are performed through the custodian’s
billing system based on the client’s written authorization. Because fee calculations are performed at the
custodial level, TVAMP does not manually adjust account values for billing purposes. TVAMP reviews
advisory fee calculations for reasonableness and accuracy as part of its supervisory process.
The maximum annual advisory fee for asset management services is 2.00% of assets under
management. TVAMP generally requires a minimum account size of $50,000, although this minimum
may be waived at TVAMP’s discretion.
Asset Management Services
TVAMP may charge advisory fees based on one of the following methods, as specified in the client
agreement.
Tiered Asset-Based Fee Schedule
Account Value
Maximum Annual Fee
First $100,000
Up to 2.00%
Next $200,000
Up to 1.75%
Next $450,000
Up to 1.50%
Next $750,000
Up to 1.25%
Assets above $1,500,000
Up to 1.00%
TVAMP may also charge a flat annual fee or flat dollar fee, depending on the services provided and the
agreement with the client.
Clients authorize the qualified custodian of their account to deduct advisory fees directly from the
account.
Wrap Fee Program
TVAMP sponsors the TVAMP Asset Management Program, a wrap fee program offered through LPL
Financials’ Strategic Wealth Management platform.
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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Under the wrap fee program, clients pay a single asset-based fee that includes investment advisory services
and most transaction costs associated with the account. Because wrap fees include transaction costs, clients
may pay more or less than they would in a traditional brokerage account depending on the level of trading
activity.
The maximum annual advisory fee for the wrap fee program is 2.00% of assets under management, although
the actual fee charged is negotiable and disclosed in the client agreement.
Additional information regarding the wrap fee program is provided in the TVAMP Wrap Fee Program Brochure
(Form ADV Part 2A Appendix 1).
LPL Advisory Programs
TVAMP may recommend advisory programs sponsored by LPL Financial. Fees for these programs vary
depending on the specific program selected and may include a combination of program fees, strategist fees,
and adviser fees..
Maximum program fees are generally as follows:
Manager Access Select
Optimum Market Portfolios
Personal Wealth Portfolios
Model Wealth Portfolios
Guided Wealth Portfolios
2.5%
2.5%
2.5%
2.6%*
1.35%*
*
Detailed information regarding each program, including fee structures and conflicts of interest, is provided
in the applicable LPL program brochure, which clients receive prior to enrolling in the program.
TVAMP receives compensation when clients participate in LPL-sponsored advisory programs, and the amount of
compensation varies depending on the program selected. These differences are based on the fee structure of
each program and the associated arrangements with LPL. As a result, TVAMP may receive higher compensation
from certain programs than from others or than from other advisory arrangements. This creates a financial
incentive for TVAMP to recommend programs that result in higher compensation. TVAMP addresses this conflict
through its fiduciary duty to act in the client’s best interest and through supervisory review of investment
recommendations.
Other Fees and Expenses
In addition to TVAMP’s advisory fees, clients may incur other fees and expenses associated with investment
products and brokerage services. These may include brokerage transaction charges, mutual fund or ETF
expenses, variable annuity fees, retirement plan administration fees, custodial charges, and other account-
related expenses.
Certain mutual funds charge distribution or servicing fees commonly referred to as 12b-1 fees. These fees
are paid from the assets of the mutual fund and are described in the fund’s prospectus.
Investment adviser representatives of TVAMP are also registered representatives of LPL Financial LLC
(“LPL”), a broker-dealer. In that capacity, LPL receives 12b-1 fees associated with certain mutual fund share
classes. Although these fees are not paid directly to TVAMP, a portion of the compensation LPL receives
is shared with its registered representatives pursuant to its compensation structure. As a result, TVAMP’s
investment adviser representatives receive an indirect financial benefit from such fees...
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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This arrangement creates a potential conflict of interest because it provides an incentive to recommend
investment products or share classes that generate additional compensation. TVAMP addresses this
conflict through its fiduciary duty to act in the client’s best interest and through supervisory oversight of
investment recommendations.
Clients should review the prospectus or offering documents for any investment product to understand the
fees and expenses associated with that investment.
Accounting Liaison Services
Prior to engaging us to provide Accounting Liaison Services, the client is required to sign an Addendum to
the TVAMP Asset Management Agreement setting forth the terms and conditions, including the fees
charged for Accounting Liaison Services.
Annual fees charged for our Accounting Liaison Services range up to 1% of assets under management with
TVAMP. Fees are billed in advance (at the start of the billing period) on a quarterly calendar basis and
calculated based on the fair market value of your account as of the last business day of the previous billing
period. Any Accounting Liaison Fee is separate from and in addition to any Advisory Fee paid to TVAMP.
The total fee paid to TVAMP will never exceed 2% of assets under management with TVAMP.
Fees are negotiable based upon the type of client, the services requested, the complexity of the client’s
situation, the composition of the client’s account, other advisory services provided and the relationship of
the client and TVAMP.
Retirement Plan Advisory Fees
TVAMP charges asset-based or fixed fees for retirement plan services, as described in the service agreement
with the plan sponsor. Fees may be billed directly to the plan sponsor or deducted from plan assets by the
plan’s recordkeeper. Fees are billed in arrears based on the value of included plan assets at the end of the
billing period.
If the agreement is terminated mid-period, fees are prorated through the effective date of termination. Any
unearned prepaid fees are refunded within fourteen (14) business days, as stated in the agreement.
TVAMP does not expect to receive compensation other than the fees described in the agreement. If any
additional compensation is received (e.g., from recordkeepers or investment providers), TVAMP will offset the
compensation against its stated fees and disclose the source of the compensation in accordance with ERISA
Regulation §2550.408b-2.
Financial Planning & Consulting Services
TVAMP offers financial planning and consulting services under several fee arrangements depending on the
scope of services provided.
Hourly Fees
Financial planning services may be provided under an hourly arrangement at a rate of up to $500 per hour.
Fixed Fees
TVAMP may charge a fixed fee for financial planning engagements. Fixed fees generally range from $500 to
$8,000, depending on the complexity of the engagement.
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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Annual Financial Planning Fees
TVAMP may provide ongoing planning services for retirement accounts for a fee of up to 2.00% of assets under
advisement, billed quarterly in arrears.
Subscription Services
TVAMP may offer ongoing financial consulting services through a subscription arrangement. Subscription fees
may range up to $8,000 annually, billed monthly or as otherwise agreed with the client.
The specific fee arrangement for financial planning services will be described in the client agreement.
Third-Party Money Managers
TVAMP may recommend that clients engage the services of third-party investment managers (“Third-Party
Managers”) to provide discretionary portfolio management services. In these arrangements, the client enters
into a separate agreement directly with the Third-Party Manager, who is responsible for managing the client’s
account and making investment decisions in accordance with the client’s investment objectives, risk tolerance,
and financial circumstances.
TVAMP assists clients with evaluating and selecting Third-Party Managers based on factors such as the client’s
investment objectives, risk tolerance, account size, investment strategy, and other relevant considerations.
Once a Third-Party Manager has been selected, TVAMP remains available to help coordinate communications
between the client and the Third-Party Manager and may periodically review the overall performance of the
account and the appropriateness of the selected manager.
The Third-Party Manager typically has discretionary authority to select the securities to be purchased and sold
for the client’s account. TVAMP does not exercise trading authority over accounts managed by Third-Party
Managers unless otherwise specified in the client agreement.
TVAMP receives a portion of the advisory fee charged by the Third-Party Manager for clients referred by
TVAMP. This compensation creates a conflict of interest because TVAMP has a financial incentive to
recommend Third-Party Managers that agree to compensate the firm. TVAMP addresses this conflict by
recommending Third-Party Managers based on the client’s investment needs and by disclosing the
compensation arrangement to clients prior to entering into the advisory relationship.
Clients should be aware that there may be other Third-Party Managers available that offer similar services and
may charge lower or higher fees. Clients are not obligated to select a Third-Party Manager recommended by
TVAMP and may engage other investment advisers independently.
Each Third-Party Manager will provide clients with its own Form ADV Part 2A disclosure brochure describing
its services, fees, investment strategies, and risks. Clients are encouraged to review these materials carefully
before engaging a Third-Party Manager.
Variable Sub-Account Management Services
TVAMP may provide advisory services to the sub-accounts of certain variable annuity contracts approved for
management through LPL Financial.
Clients participating in this program pay an advisory fee of up to 2.00% annually, billed quarterly in advance
based on the value of the variable annuity contract under management.
In addition to the advisory fee charged by TVAMP, the variable annuity issuer charges internal expenses, which
may include mortality and expense charges, administrative fees, and underlying investment management fees.
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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If the variable annuity was originally purchased through the investment adviser representative in his or her
capacity as a registered representative of a broker-dealer, the representative may have received a commission
or trail compensation at the time of sale. This compensation is separate from the advisory fee charged for
ongoing management.
Services Provided Without Charge
TVAMP may provide newsletters, educational materials, and seminars to clients or prospective clients at no
charge.
Estate Planning
TVAMP may assist clients with estate planning coordination and organization of estate planning information.
Fees for estate planning services vary depending on the complexity of the engagement and will be disclosed
in the client agreement prior to the commencement of services.
Clients are not required to utilize any third-party services that may be recommended and may obtain similar
services from other professionals.
Item 6 – Performance-Based Fees and Side-By-Side Management
Performance-based fees are defined as fees based on a share of capital gains on or capital appreciation
of the assets held in a client’s account. Item 6 is not applicable to this Disclosure Brochure because we
do not charge or accept performance-based fees.
Item 7 – Types of Clients
TVAMP provides advisory services to Individuals, Entities, Pension and Profit-Sharing plans.
You will be required to execute a written agreement with TVAMP specifying the particular services in
order to establish a client arrangement with TVAMP.
Minimum Investment Amounts Required
TVAMP requires a minimum of $50,000 in order to open an account. To reach this account minimum,
clients can aggregate all household accounts. Exceptions may be granted to this minimum based on the
investment adviser representative providing the services, the type of client, the complexity of the client’s
situation, the composition of the client’s account, the potential for additional account deposits, and the
relationship of the client and the investment adviser representative.
The minimum fee generally charged for financial planning and consulting services is $500.
Third-party money managers may have minimum account and minimum fee requirements in order to
participate in their programs. Each-third party money manager will disclose its minimum account size and
fees in its Form ADV Part 2A.
For sub-account management services, TVAMP generally requires a variable annuity contract with a
minimum account value of $50,000.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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Methods of Analysis
TVAMP primarily relies on fundamental analysis and asset allocation principles when providing
investment advice.
Fundamental analysis involves evaluating factors such as economic conditions, interest rate
environments, market trends, and characteristics of specific investments including cost structure,
diversification, and historical performance.
TVAMP also evaluates third-party investment managers, model portfolios, and investment strategies
offered through institutional advisory platforms. When selecting or recommending third-party managers
or model portfolios, TVAMP considers factors such as:
Investment Philosophy and Process
•
• Historical Performance
• Risk Management Approach
• Portfolio Diversification
• Cost and Fee Structure
The firm may also consider research and analysis provided by institutional research providers, program
sponsors, or investment strategists.
Investment Strategies
TVAMP generally employs long-term investment strategies designed to align client portfolios with their
investment objectives, time horizon, and tolerance for risk. Investment recommendations are typically
based on strategic asset allocation principles intended to provide diversification across asset classes and
investment styles.
Client portfolios may include a combination of investments such as individual equity securities (stocks),
fixed income securities (bonds), mutual funds, exchange-traded funds (ETFs), model portfolios, and
third-party investment managers. In certain cases, portfolios may be managed through advisory
programs offered by institutional platform providers or through third-party managers selected based on
the client’s objectives and risk profile.
TVAMP may recommend diversified portfolios designed to pursue growth, income, capital preservation,
or a combination of these objectives. Portfolio allocations may be periodically rebalanced or adjusted
based on changes in market conditions, investment opportunities, or changes in a client’s financial
circumstances.
In some circumstances, client accounts may utilize margin, which allows clients to borrow funds from a
broker-dealer to purchase securities using the securities in the account as collateral. The use of margin
increases both the potential gains and losses of an investment and can increase the volatility of an
account. Clients who use margin will incur interest charges and must maintain minimum equity levels in
their accounts as required by the broker-dealer.
TVAMP does not typically recommend the use of margin as a primary investment strategy; however,
margin may be available within certain brokerage accounts depending on the client’s account structure
and investment objectives. Clients should carefully consider the risks associated with borrowing before
utilizing margin.
Risk of Loss
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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Investing in securities involves risk of loss that clients should be prepared to bear. The value of investments
may fluctuate due to changes in market conditions, economic developments, interest rates, and other factors
that are beyond the control of TVAMP. Clients should understand that investment strategies and investments
recommended by TVAMP involve varying degrees of risk and there can be no assurance that any investment
strategy will achieve its intended objective.
The principal risks associated with the investment strategies used by TVAMP include, but are not limited to,
the following:
Market Risk
The value of securities may fluctuate due to general market conditions, economic developments, geopolitical
events, interest rate changes, or changes in investor sentiment.
Equity Risk
Investments in individual stocks are subject to fluctuations in value due to company-specific developments,
earnings changes, industry conditions, or broader market factors.
Fixed Income Risk
Investments in bonds and other fixed income securities are subject to risks including credit risk, interest rate
risk, and the risk that the issuer may fail to meet its payment obligations.
Interest Rate Risk
When interest rates rise, the value of existing fixed income securities typically declines. Changes in interest
rates may also impact the income generated by fixed income investments.
Inflation Risk
Inflation may reduce the purchasing power of investment returns over time.
Manager Risk
When third-party investment managers, strategists, or model portfolios are utilized, their investment decisions
may not perform as expected, which could result in losses.
Retirement Plan / ERISA Fiduciary Risk
When providing services to retirement plans governed by the Employee Retirement Income Security Act of
1974 (“ERISA”), TVAMP may act as either a non-discretionary fiduciary under ERISA §3(21) or a
discretionary investment manager under ERISA §3(38), depending on the agreement with the plan sponsor.
In these roles, TVAMP provides investment recommendations or investment management services to the
plan.
Liquidity Risk
Certain investments may be difficult to sell quickly without significantly affecting the market price, particularly
during periods of market stress.
Concentration Risk
Portfolios that are concentrated in a particular security, industry, or asset class may experience greater
volatility and risk of loss than more diversified portfolios.
ETF and Mutual Fund Risk
Investments in exchange-traded funds and mutual funds are subject to the risks of the underlying securities
held by the fund as well as the investment decisions of the fund manager. These investments also include
management fees and other expenses that reduce returns.
Margin Risk
When securities are purchased on margin, clients borrow funds from a broker-dealer to purchase securities
using the securities in the account as collateral. The use of margin magnifies both gains and losses and
increases the volatility of the account. If the value of the securities in a margin account declines, the client
may be required to deposit additional funds or securities to maintain the required equity level. If a margin call
is not met, the broker-dealer may liquidate securities in the account without prior notice.
Digital Asset-Linked Investment Risk
Certain investment vehicles, such as exchange-traded funds that track bitcoin or other digital asset
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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benchmarks, may provide indirect exposure to digital assets. These investments may experience heightened
volatility, regulatory uncertainty, liquidity constraints, and tracking error risk relative to the underlying asset.
If those securities in a margin account decline in value, the value of the collateral supporting this loan also
declines, and as a result, the brokerage firm is required to take action in order to maintain the necessary
level of equity in your account. The brokerage firm may issue a margin call and/or sell other assets in
Item 9 – Disciplinary Information
Item 9 is not applicable to this Disclosure Brochure because there are no legal or disciplinary events that
are material to a client’s or prospective client’s evaluation of our business or integrity.
Item 10 – Other Financial Industry Activities and Affiliations
TVAMP is not and does not have a related person that is a broker/dealer, municipal securities dealer,
government securities dealer or broker, an investment company or other pooled investment vehicle
(including a mutual fund, closed-end investment company, unit investment trust, private investment
company or “hedge fund,” and offshore fund), another investment adviser or financial planner, a futures
commission merchant, commodity pool operator, or commodity trading advisor, a banking or thrift
institution, a lawyer or law firm, a pension consultant, a real estate broker or dealer, and a sponsor or
syndicator of limited partnerships.
We are an independent registered investment registered advisor and only provide investment advisory
services. We are not engaged in any other business activities and offer no other services except those
described in this Disclosure Brochure. However, while we do not sell products or services other than
investment advice, our representatives may sell other products or provide services outside of their role as
investment advisor representatives with us.
Registered Representative of a Broker-Dealer
Our representatives may also be registered representatives of LPL Financial, a securities broker-dealer.
You may work with your investment adviser representative in his or her separate capacity as a registered
representative of LPL Financial. When acting in his or her separate capacity as a registered
representative, your investment adviser representative may sell, for commissions, general securities
products such as stocks, bonds, mutual funds, exchange-traded funds, and variable annuity and variable
life products to you. As such, your investment adviser representative may suggest that you implement
investment advice by purchasing securities products through a commission-based brokerage account in
addition to or in lieu of a fee-based investment-advisory account. This receipt of commissions creates an
incentive to recommend those products for which your investment adviser representative will receive a
commission in his or her separate capacity as a registered representative of a securities broker-dealer.
Consequently, the objectivity of the advice rendered to you could be biased.
You are under no obligation to use the services of our representatives in this separate capacity or to use
LPL Financial and can select any broker/dealer you wish to implement securities transactions. If you
select our representatives to implement securities transactions in their separate capacity as registered
representatives, they must use LPL Financial. Prior to effecting any transactions, you are required to
enter into a new account agreement with LPL Financial. The commissions charged by LPL Financial may
be higher or lower than those charged by other broker/dealers.
TVAMP Advisor Representatives Other Business Activities – Banking or Thrift Institutions
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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TVAMP has established and will continue to establish marketing arrangements with banks and other
depository institutions whereby investment advisory services of TVAMP may be marketed through these
banks and other depository institutions, provided that such marketing is done in compliance with
applicable SEC and state regulations. Further, TVAMP may have investment adviser representatives
conducting business from and/or affiliated with a bank or other depository institution. These relationships
may create compliance issues related to consumer protection.
Third-Party Money Managers
Our representatives are also registered representatives of LPL Financial, a securities broker-dealer. As
such TVAMP may utilize Third Party Money managers that have been pre-approved by LPL Financial.
This program is designed to allow us to recommend and select third-party money managers for you.
Once you select the third-party money manager to manage all or a portion of your assets, the third-party
money manager will pay us a portion of the fees you are charged. Please refer to Item 5 for full details
regarding the programs, fees, conflicts of interest and materials arrangements when select other
investment advisers.
Insurance Agency/Agents
TVAMP is a licensed as an Insurance Agency with the state of Tennessee and Ohio. In January of 2023
TVAMP became a licensed Insurance Agency with the State of Georgia. In 2024 TVAMP became
licensed as a nonresident Insurance Agency with the State of Texas and Florida.
You may work with your investment adviser representative in his or her separate capacity as an
insurance agent though the TVAMP agency. When acting in his or her separate capacity as an insurance
agent, the investment adviser representative may sell, for commissions, general disability insurance, life
insurance, long-term care insurance and annuities to you. As such, your investment adviser
representative in his or her separate capacity as an insurance agent, may suggest that you implement
recommendations of TVAMP by purchasing disability insurance, life insurance, and long-term care
insurance
or annuities. This receipt of commissions creates an incentive for the representative to recommend those
products for which your investment adviser representative will receive a commission in his or her separate
capacity as an insurance agent. Consequently, the advice rendered to you could be biased. You are
under no obligation to implement any insurance or annuity transaction through your investment adviser
representative.
TVAMP Tax
TVAMP is affiliated with TVAMP Tax, an accounting firm that prepares tax returns, through common
ownership. This is a conflict of interest. TVAMP has an incentive to recommend TVAMP Tax to provide
tax services to its clients because it is an affiliate of TVAMP. Additionally, the compensation paid to
TVAMP Tax is based on the client’s assets managed by TVAMP. We mitigate this conflict by ensuring the
recommendation to use TVAMP Tax is in the clients’ best interest.
Educational and Media Activities of Investment Adviser Representatives
Certain investment adviser representatives may be employed in non-advisory roles outside of TVAMP,
including as university instructors or professors. Compensation received in connection with such
employment is limited to teaching services and is not related to advisory services offered by TVAMP.
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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These outside activities may create a conflict of interest to the extent that relationships developed through
such roles may result in individuals choosing to engage TVAMP for advisory services. Clients are under
no obligation to engage TVAMP as a result of any educational relationship.
In addition, certain investment adviser representatives may maintain personal media platforms, including
social media or video-sharing channels, that provide general educational content related to financial
topics. Any advisory relationship with TVAMP is established solely through a written agreement with the
firm.
Item 11 – Code of Ethics, Participation in Client Transactions & Personal Trading
Code of Ethics Summary
An investment advisor is considered a fiduciary and has a fiduciary duty to all clients. TVAMP has
established a Code of Ethics to comply with the requirements of the securities laws and regulations that
reflect its fiduciary obligations and those of its supervised persons. The Code of Ethics also requires
compliance with federal securities laws. TVAMP’s Code of Ethics covers all individuals that are classified
as “supervised persons”. All employees, officers, directors and investment advisor representatives are
classified as supervised persons. TVAMP requires its supervised persons to consistently act in your best
interest in all advisory activities. TVAMP imposes certain requirements on its affiliates and supervised
persons to ensure that they meet the firm’s fiduciary responsibilities to you. The standard of conduct
required is higher than ordinarily required and encountered in commercial business.
This section is intended to provide a summary description of TVAMP’s Code of Ethics. If you wish to
review the Code of Ethics in its entirety, you should send a written request and upon receipt of your
request, a copy of the Code of Ethics will promptly be provided to you.
Affiliate and Employee Personal Securities Transactions Disclosure
TVAMP or associated persons of the firm may buy or sell for their personal accounts, investment products
identical to those recommended to clients. This creates a potential conflict of interest. It is the express
policy of TVAMP that all persons associated in any manner with our firm must place clients’ interests
ahead of their own when implementing personal investments. TVAMP and its associated persons will not
buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by
information obtained as a result of employment or association with our firm unless the information is also
available to the investing public upon reasonable inquiry.
We are now and will continue to be in compliance with applicable state and federal rules and regulations.
To prevent conflicts of interest, we have developed written supervisory procedures that include personal
investment and trading policies for our representatives, employees and their immediate family members
(collectively, associated persons):
• Associated persons cannot prefer their own interests to that of the client.
• Associated persons cannot purchase or sell any security for their personal accounts prior to
implementing transactions for client accounts.
• Associated persons cannot buy or sell securities for their personal accounts when those
decisions are based on information obtained as a result of their employment, unless that
information is also available to the investing public upon reasonable inquiry.
• Associated persons are prohibited from purchasing or selling securities of companies in which
any client is deemed an “insider.”
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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• Associated persons are discouraged from frequent personal trading.
• Associated persons are generally prohibited from serving as board members of publicly traded
companies unless an exception has been granted TVAMP’s Chief Compliance Officer.
Any associated person not observing our policies is subject to sanctions up to and including termination.
Item 12 – Brokerage Practices
Clients are under no obligation to act on the financial planning recommendations of TVAMP. If the firm
assists in the implementation of any recommendations, we are responsible for ensuring that the client
receives the best execution possible. Best execution does not necessarily mean that clients receive the
lowest possible commission costs but that the qualitative execution is best. In other words, all conditions
surrounding the transaction execution are in your best interest. When considering best execution, we
look at a number of factors besides prices and rates including, but not limited to:
• Execution capabilities (e.g., market expertise, ease/reliability/timeliness of execution,
responsiveness, integration with existing systems of the advisor, ease of monitoring investments)
• Products and services offered (e.g., investment programs, back-office services, technology,
regulatory compliance assistance, research and analytic services)
• Financial strength, stability and responsibility
• Reputation and integrity
• Ability to maintain confidentiality.
We exercise reasonable due diligence to make certain that the best execution is obtained for all clients
when implementing any transaction by considering the back-office services, technology and pricing of
services offered.
Directed Brokerage
Clients should understand that not all investment advisors require the use of a particular broker/dealer or
custodian. Some investment advisors allow their clients to select whichever broker/dealer the client
decides. By requiring clients to use a particular broker/dealer, TVAMP may not achieve the most
favorable execution of client transactions and the practice requiring the use of specific broker/dealers may
cost clients more money than if the client used a different broker/dealer or custodian. However, for
compliance and operational efficiencies, TVAMP has decided to require our clients to use broker/dealers
and other qualified custodians determined by TVAMP.
Broker/Dealer Affiliation
TVAMP will generally require that clients establish a brokerage account with LPL Financial or Charles
Schwab & Co., Inc. (“Schwab”), (collectively “Custodians”), to maintain custody of clients’ assets and to
affect trades for their accounts. The Custodians provide brokerage and custodial services to independent
investment advisory firms, including TVAMP. For TVAMP’s accounts custodied at LPL Financial or
Schwab, the Custodians generally are compensated by clients through commissions, trails, or other
transaction-based fees for trades that are executed through the Custodians or that settle into the
Custodians’ accounts. For IRA accounts, the Custodians can charge account maintenance fees. In
addition, the Custodians also charge clients miscellaneous fees and charges, such as account transfer
fees. The Custodians charge TVAMP an asset-based administration fee for administrative services
provided by the Custodians. Such administration fees are not directly borne by clients but may be taken
into account when TVAMP negotiates its advisory fee with clients.
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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While the Custodians do not participate in, or influence the formulation of, the investment advice TVAMP
provides, certain supervised persons of ADVISOR are Dually Registered Persons. Dually Registered
Persons are restricted by certain FINRA rules and policies from maintaining client accounts at another
custodian or executing client transactions in such client accounts through any broker-dealer or custodian
that is not approved by the Custodians. As a result, the use of other trading platforms must be approved
not only by TVAMP, but also by the Custodians.
Clients should also be aware that for accounts where LPL Financial or Schwab serves as the custodian,
TVAMP is limited to offering services and investment vehicles that are approved by the Custodian and
may be prohibited from offering services and investment vehicles that may be available through other
broker- dealers and custodians, some of which may be more suitable for a client’s portfolio than the
services and investment vehicles offered through LPL Financial or Schwab.
Clients should understand that not all investment advisers require that clients custody their accounts and
trade through specific broker-dealers.
Clients should also understand that LPL Financial and Schwab are responsible under FINRA rules for
supervising certain business activities of TVAMP and its Dually Registered Persons that are conducted
through broker-dealers and custodians other than the Custodians. The Custodians charge a fee for their
oversight of activities conducted through these other broker-dealers and custodians. This arrangement
presents a conflict of interest because TVAMP has a financial incentive to recommend that you maintain
your account with LPL Financial or Schwab rather than with another broker-dealer or custodian to avoid
incurring the oversight fee.
Benefits Received by TVAMP Personnel
The Custodians make available to TVAMP various products and services designed to assist TVAMP in
managing and administering client accounts. Many of these products and services may be used to
service all or a substantial number of TVAMP’s accounts, including accounts not held with the
Custodians. These include software and other technology that provide access to client account data
(such as trade confirmation and account statements); facilitate trade execution (and aggregation and
allocation of trade orders for multiple client accounts); provide research, pricing information and other
market data; facilitate payment of TVAMP’s fees from its clients’ accounts; and assist with back-office
functions; recordkeeping and client reporting.
The Custodians also make available to TVAMP other services intended to help TVAMP manage and
further develop its business. Some of these services assist TVAMP to better monitor and service
program accounts maintained at LPL Financial and Schwab, however, many of these services benefit
only TVAMP, for example, services that assist TVAMP in growing its business. These support services
and/or products may be provided without cost, at a discount, and/or at a negotiated rate, and include
practice management-related publications; consulting services; attendance at conferences and seminars,
meetings, and other educational and/or social events; marketing support; and other products and services
used by TVAMP in furtherance of the operation and development of its investment advisory business.
Where such services are provided by a third-party vendor, the Custodians will either make a payment to
TVAMP to cover the cost of such services, reimburse TVAMP for the cost associated with the services, or
pay the third-party vendor directly on behalf of TVAMP.
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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The products and services described above are provided to TVAMP as part of its overall relationship with
LPL Financial and Schwab. While as a fiduciary TVAMP endeavors to act in its clients’ best interests,
the receipt of these benefits creates a conflict of interest because TVAMP’s requirement, request or
recommendation that clients custody their assets at LPL Financial and Schwab are based in part on the
benefit to TVAMP of the availability of the foregoing products and services and not solely on the nature,
cost or quality of custody or brokerage services provided by the Custodians. TVAMP’s receipt of some
of these benefits may be based on the amount of advisory assets custodied on the Custodians’
platforms.
Transition Assistance Benefits
LPL Financial provides various benefits and payments to Dually Registered Persons that are new to the
LPL Financial platform to assist the representative with the costs (including foregone revenues during
account transition) associated with transitioning his or her business to the LPL Financial platform
(collectively referred to as “Transition Assistance”). The proceeds of such Transition Assistance
payments are intended to be used for a variety of purposes, including but not necessarily limited to,
providing working capital to assist in funding the Dually Registered Person’s business, satisfying any
outstanding debt owed to the Dually Registered Person’s prior firm, offsetting account transfer fees
(ACATs) payable to LPL Financial as a result of the Dually Registered Person’s clients transitioning to
LPL Financials’ custodial platform, technology set-up fees, marketing and mailing costs, stationary and
licensure transfer fees, moving expenses, office space expenses, staffing support and termination fees
associated with moving accounts.
The amount of the Transition Assistance payments are often significant in relation to the overall revenue
earned or compensation received by the Dually Registered Person at his/her prior firm. Such payments
are generally based on the size of the Dually Registered Person’s business established at their prior firm
and/or assets under custody at LPL Financial. Please refer to the relevant Part 2B brochure supplement
for more information about the specific Transition Payments your representative receives.
Transition Assistance payments and other benefits are provided to associated persons of TVAMP in their
capacity as registered representatives of LPL Financial. However, the receipt of Transition Assistance by
such Dually Registered Persons creates conflicts of interest relating to TVAMP’s advisory business
because it creates a financial incentive for TVAMP’s representatives to recommend that its clients
maintain their accounts with LPL Financial. In certain instances, the receipt of such benefits is dependent
on a Dually Registered Person maintaining its clients’ assets with LPL Financial and therefore TVAMP
has an incentive to recommend that clients maintain their account with LPL Financial in order to generate
such benefits.
TVAMP attempts to mitigate these conflicts of interest by evaluating and recommending that clients use
LPL Financials’ services based on the benefits that such services provide to our clients, rather than the
Transition Assistance earned by any particular Dually Registered Person. TVAMP considers LPL
Financials’ quality and costs of services when requiring that clients maintain accounts with LPL Financial.
However, clients should be aware of this conflict and take it into consideration in making a decision
whether to custody their assets in a brokerage account at LPL Financial.
Soft Dollar Benefits
An investment adviser receives soft dollar benefits from a broker-dealer when the adviser receives
research or other products and services in exchange for client securities transactions or maintaining an
account balance with the broker-dealer.
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TVAMP does not have a soft dollar agreement with a broker-dealer or a third-party.
However, TVAMP may receive brokerage and research services from its qualified custodians. These
services are within the purview of “soft dollars” benefits pursuant to the “safe harbor” of Section 28(e) of
the Securities Exchange Act of 1934, as amended. These services are for the benefit of TVAMP in
consideration of the Adviser’s allocation of brokerage transactions made on behalf of Clients (on both an
agency and net basis) and may not directly benefit Client accounts. The receipt of soft dollar benefits
may influence.
TVAMP’s decisions regarding recommending that Clients’ establish accounts at TVAMP’s preferred
custodian, based on TVAMP’s interest in receiving brokerage services that benefit TVAMP’s business
rather than based on the Client’s interest in receiving the best value in custody services and the most
favorable execution of Client transactions. This is a potential conflict of interest.
TVAMP receives software services and technology for market research and analysis from Schwab.
TVAMP believes, however, that its recommendation of Schwab is in the best interests of its clients.
TVAMP believes that its clients do not pay more for investment transactions effected and assets
maintained at Schwab as a result of these arrangements. TVAMP’s selection is primarily supported by
the scope, quality, and price of Schwab’s services (see Item 12 “Selection and Recommendation”) and
not Schwab’s services that benefit only TVAMP.
TVAMP normally receives ancillary benefits, including: receipt of duplicate client confirmations and
bundled duplicate statements; access to a trading desk serving adviser participants exclusively; access
to block trading which provides the ability to aggregate securities transactions and then allocate the
appropriate shares to client accounts; ability to have investment advisory fees deducted directly from
client accounts; access to an electronic communication network for client order entry and account
information; receipt of compliance publications; and access to mutual funds which generally require
significantly higher minimum initial investments or are generally available only to institutional investors.
The foregoing benefits are received solely through participation in Schwab, and do not necessarily
depend upon the proportion of transactions directed to Schwab.
Handling Trade Errors
TVAMP has implemented procedures designed to prevent trade errors; however, trade errors in client
accounts cannot always be avoided. Consistent with its fiduciary duty, it is the policy of TVAMP to correct
trade errors in a manner that is in the best interest of the client. In cases where the client causes a trade
error, the client is responsible for any loss resulting from the correction. Depending on the specific
circumstances of the trade error, the client may not be able to receive any gains generated as a result of
the error correction. In all situations where the client does not cause the trade error, the client is made
whole and any loss resulting from the trade error is absorbed by TVAMP if the error is caused by the
firm. If the error is caused by the broker-dealer, the broker-dealer is responsible for handling the trade
error. If an investment gain results from the correcting trade, the gain remains in the client’s account
unless the same error involves other client account(s) that should also receive the gains. It is not
permissible for all clients to retain the gain. TVAMP may also confer with a client to determine if the client
should forego the gain (e.g., due to tax reasons).
TVAMP will never benefit or profit from trade errors.
Block Trading Policy
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We may elect to purchase or sell the same securities for several clients at approximately the same time.
This process is referred to as aggregating orders, batch trading or block trading and is used by our firm
when TVAMP believes such action may prove advantageous to clients. If and when we aggregate client
orders, allocating securities among client accounts is done on a fair and equitable basis. Typically, the
process of aggregating client orders is done in order to achieve better execution, to negotiate more
favorable commission rates or to allocate orders among clients on a more equitable basis in order to
avoid differences in prices and transaction fees or other transaction costs that might be obtained when
orders are placed independently.
TVAMP uses the pro rata allocation method for transaction allocation.
Under this procedure, pro rata trade allocation means an allocation of the trade at issue among
applicable advisory clients in amounts that are proportional to the participating advisory client’s intended
investable assets. TVAMP will calculate the pro rata share of each transaction included in a block order
and assign the appropriate number of shares of each allocated transaction executed for the client’s
account.
If and when we determine to aggregate client orders for the purchase or sale of securities, including
securities in which TVAMP or our associated persons may invest, we will do so in accordance with the
parameters set forth in the SEC No-Action Letter, SMC Capital, Inc. Neither we nor our associated
persons receive any additional compensation as a result of block trades.
Agency Cross Transactions
Our associated persons are prohibited from engaging in agency cross transactions, meaning we cannot
act as brokers for both the sale and purchase of a single security between two different clients and cannot
receive compensation in the form of an agency cross commission or principal mark-up for the trades.
Item 13 – Review of Accounts
Account Reviews
Notwithstanding the limited scope of certain engagements, TVAMP provides all Clients with continuous
access to accounts via secure third party partners that have relevant client information. Clients may view
account-related documents such as account statements and performance summaries. On a periodic
basis, TVAMP contacts each Client to remind them to review and update personal profile information
they previously provided.
Asset Managed Accounts
TVAMP will monitor discretionary accounts on an ongoing basis. Asset Managed Account reviews are
conducted annually with the client, or more often as circumstances warrant. Managed Account reviews
consider investment strategy and objectives and result in changes to strategy if necessary. Reviews are
conducted by the investment advisor representative assigned to the account with reviews performed in
accordance with your investment goals and objectives.
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Nondiscretionary
For Clients receiving non-discretionary consulting services pursuant to a limited engagement, TVAMP
does not proactively review Client accounts. Rather, portfolio reviews are conducted only upon the
express request of the Client. Clients acknowledge and agree that TVAMP provides non-discretionary
consulting services solely in response to Client-initiated inquiries and that TVAMP is under no obligation
to provide investment or portfolio strategy recommendations unless requested.
Financial Planning
Our financial planning services may terminate upon the presentation of the written plan or may continue
depending on the arrangement with the client. Our financial planning and consulting services do not
include monitoring the investments of your account(s), and therefore, there’s no ongoing review of your
account(s) under such services.
Statements and Reports
For our asset management services, you are provided with transaction confirmation notices and regular
quarterly account statements directly from the qualified custodian. Additionally, TVAMP may provide
position or performance reports to you quarterly and upon request.
Whether reports by outside money managers are provided to you will depend upon the outside money
manager.
Financial planning clients will receive reports as agreed between the client and advisor, which may
include a comprehensive written plan and progress reports over time.
You are encouraged to always compare any reports or statements provided by us, a sub-advisor or third-
party money manager against the account statements delivered from the qualified custodian. When you
have questions about your account statement, you should contact our firm and the qualified custodian
preparing the statement.
Item 14 – Client Referrals and Other Compensation
TVAMP has entered into agreements with various parties (Referring Parties) to refer clients to TVAMP. If
a referred client enters into an investment advisory agreement with TVAMP, a cash referral fee is paid to
the referring party, which is based upon a percentage of the client advisory fees that are generated. The
referral agreements between any referring party and TVAMP will not result in any charges to clients in
addition to the normal level of advisory fees charged.
When a client is referred to us by a referring party, the referring party provides the client with a copy of
our Disclosure Brochure as required by the Investment Advisers Act of 1940. The client will also
complete a Solicitor’s Disclosure Statement document. If the referring party is an unaffiliated registered
investment adviser firm, then the client will also receive a copy of the referring party’s Form ADV Part 2
Disclosure Brochure. If a referred client enters into an investment advisory agreement with TVAMP, a
referral fee is paid to the referring party. The referral relationship will not result in clients being charged
any fees over and above the normal advisory fees charged for the advisory services provided.
The referral agreements between TVAMP and referring parties are in compliance with state and federal
securities rules regarding paid solicitor arrangements.
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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Marketing Arrangements with Financial Institutions
TVAMP has established and will continue to establish marketing arrangements with banks, credit unions
and other financial institutions. In certain circumstances, the investment advisory services of TVAMP may
also be marketed through these banks, credit unions and other financial institutions, provided that such
marketing is done in compliance with applicable SEC and state regulations. Further, TVAMP may have
Advisor Representatives conducting business from and/or affiliated with a bank or other financial
institution. As a result of these marketing agreements, the financial institution may receive compensation
representing payment for the use of the facilities and equipment of the financial institution(s), in the form
of program support or rent payment and/or a portion of advisory fees or securities commissions paid to
the representatives for sales to customer/members of the financial institution.
These relationships may create compliance issues relative to consumer protection. The joint guidelines of
regulators of the depository institution call for, at a minimum, both written and verbal disclosure at or prior to
the time securities products are purchased or sold that such securities products:
• Are not insured by the Federal Deposit Insurance Corporation (FDIC) or National Credit Union
Share Insurance Fund, the Federal Deposit Insurance Corp., the National Credit Union
Administration, or any other federal or state deposit guarantee fund or other government agency;
• Not endorsed or guaranteed by the bank or credit union or their affiliates;
• Are not deposits or obligations of the depository institutions and are not guaranteed by the
•
depository institutions;
Investments and securities are subject to investment risks, including possible loss of principal
invested.
Broker Dealer Additional Compensation
TVAMP and/or its Dually Registered Persons are incented to join and remain affiliated with LPL Financial
and to recommend that clients establish accounts with LPL Financial through the provision of Transition
Assistance (discussed in Item 12 above). LPL also provides other compensation to TVAMP and its
Dually Registered Persons, including but not limited to, bonus payments, repayable and forgivable loans,
stock awards and other benefits.
The receipt of any such compensation creates a financial incentive for your representative to recommend
LPL Financial as custodian for the assets in your advisory account. We encourage you to discuss any
such conflicts of interest with your representative before making a decision to custody your assets at LPL
Financial.
Promoter Relationship with Zoe Financial, Inc.
TVAMP has entered into a written referral agreement with Zoe Financial, Inc. (“Zoe”), an SEC-registered
investment adviser. Zoe refers prospective clients to TVAMP through its online platform.
If you are referred by Zoe and engage TVAMP for advisory services, TVAMP pays Zoe a referral fee
based on a percentage of the advisory fees TVAMP receives from you. For asset-based advisory
relationships, this compensation continues for the duration of the advisory relationship. For fixed-fee or
hourly engagements, the referral compensation is paid for a limited period as specified in the referral
agreement. The referral fee is paid solely by TVAMP and does not result in any additional charge to you
or increase the advisory fee you pay.
Zoe is not authorized to provide investment advice on behalf of TVAMP or to bind TVAMP in any
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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manner. An advisory relationship is established only upon execution of a written agreement between you
and TVAMP.
This arrangement creates a conflict of interest because TVAMP shares advisory revenue with Zoe for
referred clients. Zoe also has an incentive to recommend TVAMP because it receives compensation
from TVAMP. Clients are under no obligation to engage TVAMP for advisory services.
Additional Compensation
TVAMP’s primary compensation for advisory services consists of the fees described in Item 5 of this
Disclosure Brochure. As described in Item 14, TVAMP may compensate third parties for client referrals.
TVAMP does not receive additional third-party compensation in connection with providing investment
advice, except as disclosed in this Brochure.
Please refer to Item 5 (Fees and Compensation), Item 10 (Other Financial Industry Activities and
Affiliations), Item 12 (Brokerage Practices), and Item 14 (Client Referrals and Other Compensation) for
additional information regarding compensation and related conflicts of interest.
From time to time, TVAMP or its representatives may receive expense reimbursements for travel and/or
marketing expenses from distributors or sponsors of investment or insurance products. Travel
reimbursements are typically associated with attendance at due diligence or investment training events
hosted by product sponsors. Marketing reimbursements may include support for costs related to client
events, seminars, advertising, or educational materials.
Although these reimbursements are not conditioned upon the achievement of specific sales quotas, they
are generally provided by sponsors whose products are used or may be used by clients. This creates a
conflict of interest because it presents an incentive to recommend certain products or services. TVAMP
addresses this conflict by basing all investment recommendations on the individual needs, objectives,
and best interests of its clients.
Item 15 – Custody
Custody, as it applies to investment advisors, has been defined by regulators as having access to or
control over client funds and/or securities. In other words, custody is not limited to physically holding
client funds and securities. If an investment advisor has the ability to access or control client funds or
securities, the investment advisor is deemed to have custody and must ensure proper procedures are
implemented.
TVAMP does not maintain physical possession of client cash or securities; however, pursuant to Rule
206(4)-2 of the Advisers Act, TVAMP is deemed to have limited custody of client funds because we have
the authority and ability to debit our fees directly from certain clients’ accounts.
TVAMP is also deemed to have custody when a client establishes certain types of letters of instruction or
other asset transfer authorization arrangement with their qualified custodian, authorizing TVAMP to
disburse funds to one or more third parties specifically designated by the client. TVAMP relies on SEC
guidance for firms with this type of custody, and is not subject to a surprise annual audit as TVAMP
confirms it meets the requirements of the 7- step test as established by the SEC, to avoid being subject
to a surprise annual audit.
For accounts in which TVAMP is deemed to have custody, we have established procedures to ensure all
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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client funds and securities are held by a qualified custodian in a separate account for each client under
that client’s name. Clients or an independent representative of the client will direct, in writing, the
establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the
manner in which the funds or securities are maintained. Finally, account statements are delivered directly
from the qualified custodian to each client, or the client’s independent representative, at least quarterly.
Clients should carefully review those statements and are urged to compare the statements against
reports received from TVAMP. When clients have questions about their account statements, they should
contact TVAMP or the qualified custodian preparing the statement.
When fees are deducted from an account, the custodians are responsible for calculating and deducting
the fee and remitting a portion of the fee to TVAMP. Your account statement will contain an itemization
of the formula used to calculate the fee, the amount of assets under management the fee is based on,
and the time period covered by the fee.
Item 16 – Investment Discretion
When providing asset management services, TVAMP maintains trading authorization over your Account
and can provide management services on a discretionary basis. When discretionary authority is
granted, we will have the authority to determine the type of securities, the amount of securities that can
be bought or sold, the broker or dealer to be used, and the commission rates paid for your portfolio
without obtaining your consent for each transaction.
If you decide to grant trading authorization on a non-discretionary basis, we will be required to contact you
prior to implementing changes in your account. Therefore, you will be contacted and required to accept
or reject our investment recommendations including:
• The security being recommended.
• The number of shares or units
• Whether to buy or sell
Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing
of buying or selling an investment and the price at which the investment is bought or sold. If your
accounts are managed on a non-discretionary basis, you need to know that if you are not able to be
reached or are slow to respond to our request, it can have an adverse impact on the timing of trade
implementations and we may not achieve the optimal trading price.
You will have the ability to place reasonable restrictions on the types of investments that may be
purchased in your Account. You may also place reasonable limitations on the discretionary power
granted to TVAMP so long as the limitations are specifically set forth or included as an attachment to the
client agreement.
For sub-account management services, upon receiving written authorization, TVAMP will maintain trading
authorization over your accounts. Upon receiving written authorization from you, we may implement
trades on a non-discretionary basis. This means we will be required to contact you prior to implementing
changes to your account. However, we will be responsible for making decisions regarding the timing of
buying or selling an investment and the price at which the investment is bought or sold.
Item 17 – Voting Client Securities
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TVAMP does not vote proxies on behalf of Clients. We have determined that taking on the responsibility
for voting client securities does not add enough value to the services provided to you to justify the
additional compliance and regulatory costs associated with voting client securities. Therefore, it is your
responsibility to vote on all proxies for securities held in Account.
You will receive proxies directly from the qualified custodian or transfer agent; we will not provide you with
the proxies. You are encouraged to read through the information provided with the proxy-voting
documents and make a determination based on the information provided. Although we do not vote client
proxies, if you have a question about a particular proxy feel free to contact us. However, you will have
the ultimate responsibility for making all proxy-voting decisions.
With respect to assets managed by an outside money manager, we will not vote the proxies associated
with these assets. You will need to refer to each outside money manager’s disclosure brochure to
determine whether the outside money manager will vote proxies on your behalf. You may request a
complete copy of a third-party money manager’s proxy voting policies and procedures as well as
information on how your proxies were voted by contacting TVAMP at the address or phone number
indicated on Page 1 of this disclosure document.
Item 18 – Financial Information
This item is not applicable to this brochure. TVAMP does not require or solicit prepayment of more than
$1200 in fees per client, six months or more in advance. Therefore, we are not required to include a
balance sheet for the most recent fiscal year. We are not subject to a financial condition that is
reasonably likely to impair our ability to meet contractual commitments to clients. Finally, TVAMP has not
been the subject of a bankruptcy petition at any time.
Class Action Lawsuits
You retain the right under applicable securities laws to initiate individually a lawsuit or join a class-action
lawsuit against the issuer of a security that was held, purchased, or sold by or for client. TVAMP does not
initiate such legal proceedings on behalf of clients and does not provide legal advice to clients regarding
potential causes of action against such a security issuer and whether the client should join a class-action
lawsuit. We recommend that you seek legal counsel prior to making a decision regarding whether to
participate in such a class-action lawsuit. Upon your specific instruction, we may provide assistance to
you regarding an investment history related to the security underlying the individual, or class-action,
lawsuit and may provide assistance with the completion of this portion of certain class-action paperwork.
At no time should such assistance be deemed as a substitute for consulting with legal counsel.
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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TVAMP Customer Privacy Policy Notice
The information contained in this section will also be disclosed in TVAMP’s Privacy Policy Statement.
This statement will be provided to all clients in accordance with the rules and regulations of the Gramm
Leach-Bliley Act of 1999.
As a financial services firm, TVAMP, LLC will gather and use nonpublic personal information (NPI) in
order to provide our clients (prospective, current, or former) with a broad range of financial services. We
are providing this notification to inform you of the types of NPI we collect, our privacy safeguards, and
sharing practices. We handle all NPI in accordance with this policy.
Nonpublic personal information (NPI) is confidential personal information about you that we obtain in
connection with providing financial services or products to you. Generally, NPI about you is collected
from the following sources:
•
•
•
Information contained within applications or other forms;
Information about your transactions with us, our affiliates, our service providers, or other parties
to transactions; and
Information we may receive about you from unaffiliated financial service providers (e.g.
custodians, insurance agents, attorneys, and consumer reporting agencies)
We do not disclose any NPI about you without your express consent, except as described in this notice. We only
share your NPI with:
1. Employees of our firm;
2. Affiliates of our firm, including TVAMP Tax Planning, LLC ;
3. Unaffiliated service providers (e.g. broker-dealers, banks, subadvisors, co-advisors, third-party managers,
platform providers, account aggregation services and mutual fund companies) as necessary to effect,
administer, or enforce transactions that the client has requested or authorized;
4. Professional advisors, including information technology consultants, compliance consultants, legal counsel,
accounting firms, cybersecurity providers, and other vendors, solely to the extent necessary for them to
perform services on the Firm’s behalf and to support the Firm’s fiduciary and operational responsibilities to
clients
5. Other who need to know such information in order to provide products or services to you; and
6. Any other person or entity with whom we are permitted or required by law to share it.
Disclosure of NPI is limited to what is necessary to provide advisory services to clients, administer client
accounts, fulfill legal and regulatory obligations, or otherwise conduct the Firm’s business in accordance
with applicable law.
We maintain physical, electronic, and procedural safeguards to protect your NPI, Our safeguards include
measures to protect your information prior to, during and upon termination of our financial services
engagement (i.e. disposal of your data). The Firm also conducts due diligence and ongoing oversight of
service providers with access to NPI and requires such providers to implement reasonable
administrative, technical, and physical safeguards designed to protect client information and notify the
Firm of any material security incidents affecting such information.
We do not sell, share, or disclose your personal information to persons or entities other than as
described above. We will not share or disclose such information to non-affiliated third-party marketing
companies.
When a client or prospective client account is closed, TVAMP, LLC will continue to keep all client
information confidential in accordance with the principles stated in its privacy policy.
A copy of the Privacy Policy Notice will be delivered to all clients and prospective clients in writing by at
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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least one of the following methods:
•
•
•
• By hand delivering a copy to the client or prospective client
• Mailing a copy to the client’s or prospective client’s address on record
• If business is conducted electronically, a notice may be posted on an electronic site as long as
the client or prospective client acknowledges receipt of the Privacy Policy Notice prior to the
client obtaining any services or products from TVAMP, LLC
Any time a change is made to the Privacy Policy, the statement to clients or prospective clients will be
revised. The revised statement will be given to all affected clients prior to any disclosure of information.
In addition, TVAMP, LLC will provide a copy of its Privacy Policy Statement to all current and existing
clients or prospective clients as required by law.
If you have any questions regarding our privacy policy, please do not hesitate to contact your investment
adviser representative or you may write to, email, or call us at:
Jeffrey.Foster@tvamp.com
865-226-9982
TVAMP, LLC
6028 Brookvale Lane
Suite 160
Knoxville, TN 37919
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
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Office Locations
6154 Popes Creek Place
Haymarket, VA
703-754-2839
11566 Chapman Highway
Seymour, TN 37865
(865) 577-1922
4273 Olde Mill Ln NE
Atlanta, GA 30342
306 Main Street
Jacksboro, TN 37757
(423) 566-4000
1113 Hunter’s Crossing
Alcoa, TN 37701
(865) 226-9982
1339 Volunteer Parkway
Bristol, TN 37620
(865)544-5400
(865) 544-5400
662 E. Broadway Blvd
2004 N. Roan Street
Jefferson City, TN 37760
Johnson City, TN 37601
(865) 544-5400
(865) 544-5400
4611 Kingston Pike
2518 E. Stone Drive
Kingsport, TN 37660
Knoxville, TN 37919
(865) 544-5400
(865) 544-5400
31 Market Square
7459 Maynardville Pike
Knoxville, TN 37902
Knoxville, TN 37938
(865) 544-5400
(865) 544-5400
4118 Asheville Hwy
1974 Town Center Blvd
Knoxville, TN 37922
Knoxville, TN 37914
(865) 544-5400
(865) 544-5400
1316 Wilson Rd
4520 Greenway Drive
Knoxville, TN 37912
Knoxville, TN 37918
(865)544-5400
(865)544-5400
455 Market Drive
2325 Market Place Drive
Lenoir City, TN 37771
Maryville, TN 37801
(865) 544-5400
(865)544-5400
3101 Millers Point Drive
5327 Winner’s Circle Rd
Morristown, TN 37813
Morristown, TN 37813
(865)544-5400
(865)544-5400
4310 Winkler Ave
1916 Roane State Highway
Morristown, TN 37814
Harriman, TN 37748
(865)544-5400
(865)544-5400
1037 Middlecreek Rd
7210 Chapman Hwy
Sevierville, TN 37862
Knoxville, TN 37920
(865)544-5400
(865)544-5400
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
Page 37
ADDITIONAL LOCATIONS – continued
5271 Highway 11E
Piney Flatts, TN 37686
(865) 544-5400
7515 Central Avenue Pike
Powell, TN 37849
(865) 544-5400
11490 Parkside Drive
102 N Seven Oaks Drive
Farragut, TN 37934
Knoxville, TN 37922
(865)544-5400
(865)544-5400
711 W 1st North St.
Morristown, TN 37814
(423) 616-0182
TVAMP, LLC Form ADV Part 2A Disclosure Brochure
Page 38