Firm Description
Transatlantique Private Wealth, LLC (“TPW;” the “Firm;” “Adviser”) is a New York
limited liability company and an SEC registered investment advisory firm with its
office in New York, New York. The Firm was formed in December 2013 and
commenced business operations on April 4, 2014.
TPW is wholly owned by Banque Transatlantique S.A., a bank headquartered in
Paris, France (“Banque Transatlantique”), that specializes in private banking services
and wealth management. Banque Transatlantique is a wholly owned subsidiary within
the Credit Mutuel Alliance Federale group of companies domiciled in France and
Europe. Banque Transatlantique is owned 100% by CIC (Credit Industriel et
Commercial), which in turn is 94% owned by Banque Federative de Credit Mutuel
(“BFCM”), which itself is 93% owned by Caise Federale de Credit Mutuel.
As of December 31, 2023, TPW manages approximately $595,329,700 in
Regulatory Assets Under Management, $586,185,426 on a discretionary and
$9,144,274 on a non-discretionary basis.
Types of Advisory Services
TPW provides investment advisory services on a non-discretionary and discretionary
basis primarily to high net worth individuals with international investment exposure.
TPW is in a position to assist such investors to maneuver through the cross-border
intricacies between the USA and France. Accordingly, the Firm’s target client base is
mainly French expatriates in the United States and U.S. persons owning euro
denominated assets and property. The Firm creates asset allocation plans for its clients
and assists them to distribute their investments across the various asset classes. TPW is
also able to offer tailored advice that leverages the expertise of TPW’s affiliated
companies in France and Europe.
The Firm’s advisory services are typically provided to individual clients as an ongoing
service pursuant to an Advisory Agreement. Such services may include advice and
guidance on debt management; currency management; risk management; long-term
project funding; executive compensation; stock options and RSUs; and, investment
portfolio construction. The investment advisory fee is the only fee the Firm charges
(see Item 5: Fees and Compensation).
In some instances, advice may be provided as a limited engagement that focusses on a
specific investment or financial issue, rather than comprehensive portfolio
management, at the request of the client and at the sole discretion of the Adviser.
The Firm may also provide to certain high-net worth individuals the opportunity to
have their portfolios managed by a sub-adviser, which may be engaged by the Firm.
TPW would monitor the performance of any such independent manager on behalf of
the advisory client, in terms of the manager’s authority to operate in the jurisdiction in
which the client resides as well as in terms of matters including the manager’s expertise
relative to the client’s needs.
TPW also advises two commingled investment vehicles: The Philippe Fund Euro
Global Leaders, LLC and The Philippe Fund U.S. Equities, LLC (together the
“Commingled Funds”). Certain TPW clients, who are deemed ‘accredited investors,’
may invest in the Commingled Funds, pursuant to a subscription agreement.
All clients are required to sign an Advisory Agreement outlining the terms and
conditions of the engagement as described below. TPW will provide a copy of this
Brochure (Form ADV Part 2) to each client prior to the execution of an Advisory
Agreement. Any client, who does not receive a copy of the current TPW Brochure at
least 48 hours prior to executing the Advisory Agreement, is permitted five business
days to rescind the engagement without penalty.
TPW does not at this time participate in wrap fee programs, whether recommending
that its clients participate in them or by providing portfolio management services to
such programs.
Tailored Relationships and Restrictions
The nature of TPW’s primary advisory business is that it tailors its advisory services to
the specific needs of the client. Based on suitability information gathered for a
particular client, including financial condition, investment objectives, investment risk
profile and other factors that may be relevant to the proposed investments by a client,
TPW will advise the client about the allocation of their assets into specific investments
across different forms of investments and investment managers, including, without
limitation, designation of other portfolio managers, who will actually invest and
reinvest within specified asset classes on behalf of the client. There is no minimum
portfolio size. (see Item 5: Fees and Compensation below). In terms of the Firm’s
advisory fee schedule, current client relationships may exist where the fees are higher
or lower than the fee schedule, due to a negotiated rate. However, in no event would the
TPW advisory fee charged to a client ever be greater than 3% of client Assets Under
Management (“AUM”).
On an ongoing basis, the Firm will monitor the performance in a client’s portfolio after
the initial Asset Allocation Plan is implemented and report that performance to the
client, whether monthly, quarterly, or at intervals requested by the client. TPW would
also recommend from time to time modifications to the Plan.
In the context of this asset allocation approach, TPW will tailor its services to the needs
and desires of the individual client.
Clients may ask that certain investment restrictions be placed on their Accounts. It is
the policy of TPW to agree to client-imposed investment restrictions only if the clients
and TPW are able to agree upon restrictions that are clear and actionable. TPW will
ensure that where possible the advisory client will provide a list of prohibited securities
(e.g., Anheuser Busch, etc., instead of a list of types of prohibited securities such as
"sin stocks," etc.). Where only restrictions on the types of securities are agreed-to, TPW
requires as much written specificity as possible (e.g., brewing of alcoholic beverage or
distribution of liquor, or both). Where a client places specific restrictions on the
Account, there will be a specific contractual provision in the Advisory Agreement
addressing prohibited investments that obligates TPW to make its “best efforts” to
comply with the client restriction since the vast majority of client investments will be
managed by mutual fund managers not associated with TPW.
Investment & Wealth Advisory Services
TPW’s ongoing advisory services
can be enhanced for wealthier clients into an overall
analysis of the client’s financial circumstance. These services are typically provided to
clients with net worth in excess of U.S. $1,000,000 and/or with the specific need for
professional expertise in regard to the cross border financial issues affecting the United
States and France. No additional fee would be charged for such services.
TPW will propose an asset allocation plan based on a suitability profile derived from a
thorough review of the client’s financial situation and objectives as well as the client’s
level of risk aversion. With this information in hand the Adviser is able to leverage the
asset allocation modeling developed by TPW’s affiliate, Dubly Transatlantique
Gestion, a Paris based adviser, and the mutual fund analysis and recommendations
developed by the Credit Mutuel Alliance Federale asset management teams based in
Paris, Brussels, and Luxembourg.
Independent Managers
TPW may recommend that a client allocates a portion of its assets across independent
investment managers, unaffiliated with TPW, in accordance with the client’s approved
asset allocation plan. In such situations, the independent managers would have primary
day-to-day management responsibilities for the active discretionary management of the
allocated assets in a separate Account. TPW would remain responsible for monitoring
the performance of these sub-advisers on behalf of the advisory client to ensure that the
Account remains properly allocated, and the investment objectives of the client and
performance of the Account remain in accordance with the overall plan. Factors that
TPW considers in recommending these sub-advisers include the client’s investment
objectives, the adviser’s management style, performance, reputation, financial strength,
reporting, costs, and research capabilities.
Limited Engagements
Generally, the Firm does not enter into limited engagements. However, if the Firm were
to enter into a limited engagement, the scope of the work would be clearly defined and
the engagement would be terminated upon delivery of the contracted advice. TPW does
not typically provide an overall client profile and investment plan in conjunction with
its investment advisory services pursuant to a limited engagement. Rather, the focus is
on providing analysis and actionable recommendations relating to financial decisions
of an immediate nature to the client.
Implementation
TPW offers investment advice on a discretionary and non-discretionary basis. For
accounts managed on a non-discretionary basis, the advisory client makes all final
decisions regarding the implementation of investment recommendations, including the
determination of the timing and execution of portfolio trades. TPW provides its advice
and the client retains absolute discretion over the implementation of portfolio
management. The client is always free to accept or reject and recommendation by TPW.
For accounts managed on a discretionary basis, please refer to Item 16. Investment
Discretion within this brochure (page 26).
Private Fund Adviser
TPW advises two commingled private investment vehicles: The Philippe Fund Euro
Global Leaders, LLC and The Philippe Fund U.S. Equities, LLC (together the
“Commingled Funds”). Certain TPW clients, who are deemed ‘accredited investors,’
may invest in the Commingled Funds, pursuant to a subscription agreement.
Other Services
TPW may provide as part of its advisory services to its clients information regarding
non-investment related matters, such as estate planning, insurance, etc. No additional
fee would be charged for such services. Neither TPW, nor any of its representatives or
affiliates, purports to provide accounting advice. To the extent requested by an advisory
client and within the available expertise of the Firm, TPW may recommend the services
of other professionals for certain non-investment implementation purposes (i.e.
attorneys, accountants, etc.). The advisory client, of course, retains absolute discretion
over all such implementation decisions and is free to accept or reject any
recommendation from TPW.
Advisory Agreement
TPW does not conduct Financial Planning or Tax Preparation services. TPW’s
traditional business model is to offer clients asset allocation construction services and
recommendations regarding mutual fund managers across the agreed-upon asset
classes.
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Investment Advisory Agreements and Disclosure of Conflicts of Interest
All clients receive and sign the Advisory Agreement at the commencement of the
advisory relationship. The Firm will work with the client to understand the client’s
suitability profile and will develop with the client an asset allocation plan, whereby the
TPW portfolio manager will then recommend various mutual funds, exchange-traded
funds (“ETFs”), and structured products to satisfy the requirements of each asset class
recommended or will recommend external portfolio managers.
Conflicts of Interest
One of the main purposes of this Form ADV Part 2A and the Advisory Agreement is
for TPW to be able to fully and properly present its investment advisory services AND
to fully and clearly disclose any material conflicts of interest that may exist between
the interests of the Adviser and the advisory client. State and federal laws and
regulations provide that failing to disclose to an advisory client in writing before
entering or renewing an advisory agreement with that client any material conflicts of
interest regarding the Adviser, its representatives or any of its employees, which could
be reasonably expected to impair the rendering of unbiased and objective advice does
not promote fair, equitable or ethical principles. Accordingly, both this Form ADV Part
2A and the Advisory Agreement are intended by the Adviser to disclose all material
conflicts of interest to the advisory client.
Termination of Agreement
TPW’s Advisory Agreements can be terminated by either the client or the Firm, upon
written notice of termination from either party to the other, or as otherwise agreed
between the client and TPW. If termination occurs other than at the end of a quarter,
TPW will be entitled to its investment advisory fee for the portion of the quarter elapsed
prior to termination, pro-rated based on the actual number of calendar days in that
specific calendar quarter and the actual number of calendar days elapsed in that
calendar quarter.