This Disclosure document is being offered to you by Triumph Capital Management (“TCM”) in
connection with the investment advisory services TCM provides. This ADV Part 2A discloses
information about the services that are provided by TCM, its Investment Advisor Representatives
(“IARs”), and the way those services are made available to you, the client.
TCM is an investment management firm with office sites located in Denver, CO; Louisville, CO;
and Malibu, CA. TCM’s headquarters is located at 1610 Wynkoop Street, Suite 550, Denver, CO
80202. TCM specializes in investment advisory services for individuals, families, trusts, estates,
retirement accounts, pension plans, and profit-sharing plans. The firm was established by Mr. Derek
Eichenwald, the firm’s principal owner, in 2016.
TCM is committed to helping clients build, manage, and preserve their wealth by providing strategic
assistance to help clients achieve their stated financial goals. TCM may offer an initial complimentary
meeting upon our discretion; however, investment advisory services are initiated only after you and TCM
execute an engagement letter or one of TCM’s client agreement forms.
• Website:
www.TriumphCapitalManagement.com
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www.linkedin.com/company/3268630/
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Investment Management and Supervision Services
TCM offers discretionary investment management and investment supervisory services for a fee based on
a percentage of your assets under management. These services include investment analysis, allocation of
investments, quarterly and monthly portfolio statements, financial commentaries, and ongoing monitoring
of client portfolios.
TCM will help in determining your portfolio composition based on your needs, portfolio restrictions, if
any, financial goals, and risk tolerances. TCM will work with you to obtain necessary information
regarding your financial condition, investment objectives, liquidity requirements, risk tolerance, time
horizons, and any restrictions on investing. This information enables TCM to determine the portfolio best
suited for your investment objectives and needs.
While performing services, TCM shall not be required to verify any information received from you or
from other professionals about you. If you request, TCM may recommend and engage the services of
other professionals for implementation purposes. You have the right to decide whether to engage the
services of any such recommended professional.
Once TCM has determined the types of investments to be included in your portfolio and allocated them,
TCM will then provide ongoing portfolio reviews and management services to you. This approach
requires us to periodically review your portfolio.
TCM’s advisory services are tailored to meet the needs of its clients and seek to ensure that client
portfolios are managed in a manner consistent with those needs and objectives. You will have the ability
to leave standing instructions with TCM to refrain from investing in industries or invest in limited
amounts of securities in the investment management agreement.
In all cases, you have a direct and beneficial interest in your securities, rather than an undivided interest in
a pool of securities. TCM has limited authority to direct the custodian to deduct our investment advisory
fees from your account(s). Only with the appropriate authorization, as indicated on your client agreement
with TCM, can such fees be deducted.
You are advised and are expected to understand TCM’s past performance is not a guarantee of future
results. Certain market and economic risks exist that may adversely affect an account’s performance. This
could result in capital losses in your account. Risks are further described in Item 8 of this Brochure.
For assets held in a multi-participant 401(k) account, TCM offers discretionary investment consulting. In
these accounts, the client retains the right to act or not to act on the recommendations made by TCM.
TCM’s advisory services are limited to recommendations for the purchase of investments for your
account or sale of investments in your account, which in each case TCM believes would be appropriate
for your account considering the agreed-upon investment objectives, risk tolerance, and restrictions if
applicable. The client acknowledges that they are responsible for all purchases and sales made in their
account(s).
You should be aware the compensation to TCM and your IAR will diverge per the advisory program
chosen. This compensation to TCM and your IAR may be more than the amounts TCM would otherwise
receive if you participated in another program. Because of the differences in fee schedules among the
various advisory programs and services offered by TCM through your IAR, there is a financial incentive
to recommend a program or service over another program or service offered. Additionally, TCM has a
financial incentive to recommend rolling over assets not managed by TCM to accounts that are managed
by TCM and its IARs. This presents a conflict of interest because there may be an incentive to make
recommendations based on the amount of compensation that TCM will receive rather than based on
your needs. Your IAR will explain the specific costs of all programs recommended to you and it will
also be outlined in your agreement with TCM.
Managed by Triumph Capital Management at Security Benefit
The Managed by TCM at Security Benefit Program utilizes six models to manage client accounts that
are opened and held at Security Benefit. The mutual funds that are available on the Security Benefit
platform will be the only options available in the allocation mix of these models. On a monthly basis,
the models are reviewed, and the investments inside of the model are reallocated. However, the models
may remain the same and may not be reallocated at the discretion of the manager and his/her team if
they determine that the current allocation is appropriate.
Tactical Model at Security Benefit: The Tactical model at Security Benefit seeks to provide absolute
returns during any market cycle or condition by employing a strategic rotation model between
commodities, REITs, bonds and other fixed income investments, international equities, domestic equities,
and cash. Utilizing the funds available on the Security Benefit platform, the Tactical model will select and
weigh heavily into a selection of asset classes from the categories listed above that TCM believes is
experiencing the most strength, while attempting to avoid those asset classes which the manager and
his/her team believe are in a downward trend or do not show as much promise to the upside.
Conservative Model at Security Benefit: The Conservative model at Security Benefit seeks to protect
principal over seeking appreciation. Utilizing the funds available on the Security Benefit platform, the
Conservative model focuses on an investment strategy that emphasizes capital preservation and risk
minimization through a diversified and balanced portfolio of commodities, REITs, bonds and other fixed
income investments, international equities, domestic equities, and cash.
Moderate-Conservative Model at Security Benefit: The Moderate-Conservative model at Security Benefit
values principal preservation but will accept a small degree of risk and volatility to seek some degree of
appreciation. The Moderate-Conservative model seeks to accept lower returns, while accepting minimal
losses. Utilizing the funds available on the Security Benefit platform, the Moderate-Conservative model
focuses on an investment strategy through a diversified and balanced portfolio of commodities, REITs,
bonds and other fixed income investments, international equities, domestic equities, and cash.
Moderate Model at Security Benefit: The Moderate model at Security Benefit seeks to reduce risks and
enhance returns equally. The Moderate model accepts modest risks to pursue higher long-term returns and
may endure a short-term loss of principal in exchange for long-term appreciation. Utilizing the funds
available on the Security Benefit platform, the Moderate model focuses on an investment strategy through
a diversified and balanced portfolio of commodities, REITs, bonds and other fixed income investments,
international equities, domestic equities, and cash.
Aggressive-Moderate Model at Security Benefit: The Aggressive-Moderate model at Security Benefit
values higher long-term returns and is willing to accept significant risk. The Aggressive-Moderate model
is willing to endure large losses in favor of potentially higher long-term returns. Utilizing the funds
available on the Security Benefit platform, the Aggressive-Moderate model focuses on an investment
strategy through a diversified and balanced portfolio of commodities, REITs, bonds and other fixed
income investments, international equities, domestic equities, and cash.
Aggressive Model at Security Benefit: The Aggressive model at Security Benefit seeks to maximize
returns and is willing to accept substantial risk. The Aggressive model is willing to risk losing money to
achieve potentially better results. Utilizing the funds available on the Security Benefit platform, the
Aggressive model focuses on an investment strategy through a diversified and balanced portfolio of
commodities, REITs, bonds and other fixed income investments, international equities, domestic equities,
and cash.
All six models involve risk including the loss of principal. Past performance is not a guarantee of future
results. The Managed by TCM at Security Benefit models may not achieve their goals. Market and
economic risk may adversely affect the Managed by TCM at Security Benefit models that could result in
capital losses in your account. Investing involves risk of loss which you should be prepared to bear.
Please consider the charges, risks, expenses, limited investment options, and your overall objectives
carefully before investing in any of the Managed by TCM at Security Benefit models. The mutual funds,
ETFs, and/or sub-accounts that are available on the Security Benefit platform will be the only options
available in the allocation mix in these models. The Managed by TCM at Security Benefit models are
not intended to manage all client assets or to address all of their needs. The models intend to provide
clients, who are suitable and have a covered account with Security Benefit, options for managing those
assets.
Accounts enrolled in the Managed by TCM at Security Benefit program will be managed inside of the
model selected on the client agreement but may change based on the client’s ongoing investment
objectives and goals. Model allocations are not personalized to individual investors. Accounts in the
Managed by TCM at Security Benefit models are custodian with Security Benefit. Clients should receive
at least quarterly statements from Security Benefit. TCM urges you to carefully review these statements
and compare them to the account statements that TCM may provide you, if applicable. You should verify
that the transactions in your account are consistent with your investment goals and the objectives for your
account. TCM also encourages you to contact your IAR or our Chief Compliance Officer should you
have any questions or concerns regarding your account.
The Managed by TCM at Security Benefit Program is limited in nature and is not intended to address all
your advisory needs. Additional services are available by separate agreement. Please review this
brochure thoroughly and consult with your IAR about the additional services that are available to you.
Inclusion in this program is limited and subject to TCM’s discretion. TCM may prohibit any person
from participating for any reason or no reason at all.
Third Party Asset Managers
TCM provides investment advice and recommendations on the investment strategies of Third-Party Asset
Managers (“TPAM” or “Managers”). Selected Managers are evaluated by TCM for client use. TCM’s
services include assisting you in identifying your investment objectives and matching personal and
financial data with a select list of Managers. The intent of this service is to have a selected list of high-
quality third-party investment management firms from which TCM selects one or more Managers to
handle the day-to-day management of your account(s).
TCM’s IARs assist you with identifying your risk tolerance and investment objectives. IARs will
recommend Managers in relation to your stated investment objectives and risk tolerance. TCM helps
you select a recommended Manager based upon your needs. TCM may act in either a “Manager of
Managers” or “sub-advisor” capacity when it offers TPAM programs to you.
Managers selected for your investments need to meet several quantitative and qualitative criteria
established by TCM. Among the criteria that may be considered are the Manager’s experience, assets
under management, performance record, client retention, the level of client services provided, investment
style, buy and sell disciplines, capitalization level, and the general investment process.
You are advised and should understand that:
• A Manager’s past performance is no guarantee of future results.
• There is a certain market and/or interest rate risk which may adversely affect any Manager’s
objectives and strategies, and could cause a loss in a client's account(s); and
• Client risk parameters or comparative index selections provided to TCM are guidelines only, and
there is no guarantee that they will be met or not be exceeded.
TCM’s IARs shall be available to answer questions you may have regarding your account and act as the
communication conduit between you and the Manager. Managers may take discretionary authority to
determine the securities to be purchased and sold for the client.
Information collected by TCM regarding Managers is believed to be reliable and accurate, but TCM
does not necessarily independently review or verify it on all occasions. Performance reports may be
produced by the respective Manager. Such performance reports will be provided directly to you and
TCM. TCM does not audit or verify that these results are calculated on a uniform or consistent basis as
furnished by a Manager directly to TCM or through
the consulting service utilized by the Manager.
However, TCM does monitor the results of the Manager.
TCM has entered into agreements with various independent program Managers. Under these agreements,
TCM offers clients various types of programs sponsored by these Managers. All TPAMs to whom TCM
will refer you will be licensed as investment advisors by your resident state and any applicable
jurisdictions or registered investment advisors with the Securities and Exchange Commission.
TPAMs generally have account minimum requirements that will vary from investment advisor to
investment advisor. A complete description of the Manager’s services, fee schedules, and account
minimums will be disclosed in the Manager’s Form ADV or similar disclosure brochure which will be
provided to clients before an agreement for services is executed and the account is established.
Manager of Managers: When acting as a Manager of Managers for the TPAM program, your IAR assists
you in selecting one or more TPAM programs believed to be suitable for you based on your stated
financial situation, investment objectives, and financial goals. TCM and your IAR oversee your
investment with the TPAM. TCM can track the performance of each Manager and has the authority to fire
ineffective Managers and hire replacements on your behalf. TCM and your IAR are compensated for
referring you to the TPAM program. This compensation generally takes the form of the TPAM sharing a
percentage of the advisory fee you pay to the TPAM with TCM and your IAR. You will receive a written
disclosure statement describing the nature of our relationship with the TPAM program, if any; the terms
of our compensation arrangement with the TPAM program, including a description of the compensation
that TCM will receive for referring you to the TPAM program; and the amount, if any, that you will be
charged in addition to the advisory fee that you will pay to the TPAM as a result of our referral of you to
the TPAM program. As part of establishing a new account, you will receive TCM’s disclosure brochure
as well as the TPAM’s disclosure brochure.
Advisor of Sub-Advisor: Under an advisor or sub-advisor relationship between TCM and the sponsor of
the TPAM program, TCM and the sponsor are jointly responsible for the ongoing management of the
account. Your IAR is responsible for assisting you with completing the investor profile questionnaire.
While each TPAM may have a different name for the questionnaire, your responses will assist the IAR
with understanding your investment objectives, financial situation, risk tolerance, investment time
horizon and other personal information. Based on the information that you provide to the IAR, he or she
will assist you in determining which TPAM model or portfolio strategy is appropriate for you.
Triumph Turnkey Asset Management Program
Similar to outside TPAMs, TCM offers Triumph Turnkey Asset Management Program (“TTAMP”) that
is available to unaffiliated IARs, and licensed Financial Professionals (“FP”) to utilize when evaluating
investment options for their clients. TCM IARs are also able to enroll their clients in the TTAMP.
Inside and outside FPs and IARs can access TTAMP which provides model portfolios and other
portfolio management solutions that are managed by TCM.
Clients enrolled in the TTAMP will pay TCM a monthly or quarterly fee to cover the cost of
administering the program and for providing portfolio management. A portion of the TTAMP fee may
be shared with the account custodian for providing custody, clearing, and other services.
TCM will typically not accept a client into the program that is not introduced by a FP or IAR. The
services to be provided and the expectations of the client, FP, IAR, and TCM are outlined in the client
agreement, which may be amended in writing from time to time. Clients are free to direct the account in
any manner that meets their objectives to include determining the asset allocation, models that may be
used, as well as any restrictions the client wishes to place on the account. Full model allocation may be
limited due to account size. Small account values may result in allocation variances that deviate from
the intended TTAMP model.
The introducing FP or IAR serves as a liaison between TCM and the client, and is responsible for
gathering and communicating the client’s financial information, risk tolerance, and investment objectives.
Clients grant TCM discretionary authority to place trades for the account and when appropriate – relative
to the client’s investment objectives or any restrictions placed on the account by the client – to make
changes to the asset allocation or model selection. By executing a Limited Power of Attorney, clients may
also grant their FP or IAR the authority to effect changes to the account such as the model selection. Once
an account is established, TCM continuously monitors the asset allocation and/or models and executes
trades for the account. The FP or IAR will continue to service the client relationship by meeting with the
client at least annually and communicating to TCM any necessary changes to the client’s account. For
these reasons, the client should acknowledge information sharing between the FP, or IAR and TCM,
which can include personal non-public information.
FPs and IARs may provide other clerical or administrative duties for the client’s account and may also
provide other services outside and in addition to the services offered through the program. This brochure
describes the products and services offered by TCM and its IARs only. Since FPs and IARs may offer
other third-party services in conjunction with, or outside those provided through the program, clients
should read and review the introducing firm’s disclosure brochure to fully understand the services being
rendered to the client by the introducing firm through the FP or IAR.
You should be aware that the compensation to TTAMP and your IAR may be more than the amounts you
would otherwise pay if you participated in another TPAM program. Because of the differences in fee
schedules among the various advisory programs and services offered by TCM through your IAR, there is
a financial incentive to recommend the TTAMP service over another TPAM program or service. This
presents a conflict of interest because there may be an incentive to make recommendations based on the
amount of compensation that TCM and the IAR receive rather than based on your needs. Your IAR will
explain the specific costs of all programs recommended to you, and it will also be outlined in your
agreement with TCM.
Client Information Provided to Portfolio Managers and Client Contact
Non-public information is information about you not accessible to the public. Your social security
number, net worth, and annual income are examples of non-public information. Public information is
information about you readily accessible to the public. Public information may include your name, phone
number, and address.
For all accounts, including those in the programs described in this brochure, your IAR will have access to
the non-public information provided by you in the account opening process. This information is protected
in accordance with TCM’s Privacy Policy. TCM’s Privacy Policy is available on TCM’s
website and is
provided upon opening your account and annually thereafter.
Retirement Plan Advisory Services
Retirement Plan Advisory Services consist of assisting employer plan sponsors to establish, monitor, and
review their company's retirement plan. As the needs of the plan sponsor dictate, areas of advising could
include investment selection and monitoring, plan structure, and participant education.
TCM will help establish your plans needs and objectives through an initial meeting to collect data, review
plan information, and assist you in developing or updating the plans provisions. Ongoing services to you
may include recommendations regarding the selection and review of unaffiliated mutual funds, ETFs, and
other investment products that, in TCM’s judgment, are suitable for the investment of plan assets. TCM
will periodically review the investment options you select and make recommendations to keep or to
replace plan investment options as TCM feels appropriate. TCM will perform a comprehensive review of
potential service providers or vendors and will assist you with converting from your incumbent service
provider to a new service provider selected by you. You are under no obligation to follow the
recommendations that TCM may make.
Services available under an investment advisory agreement may permit TCM to provide financial
education to your plan participants. The scope of education provided to participants at your request will
not constitute “investment advice” within the meaning of ERISA, and participant education will relate to
general investment principles and information about the investment options currently in the plan. TCM
may also participate in initial enrollment meetings, periodic workshops, and future enrollment meetings
for new participants as agreed upon.
All Retirement Plan Advisory Services shall be in compliance with all applicable Federal and State
law(s) regulating the services provided by our agreement. This section applies to an account that is a
pension or other employee benefit plan governed by ERISA. If your account is part of a qualified plan
and TCM accepts appointments to provide our services to your account, TCM acknowledges that it is a
fiduciary within the meaning of Section 3(21) of ERISA and within the meaning of Section 4975 of the
Internal Revenue Code. Furthermore, TCM agrees to comply with the Department of Labor’s Impartial
Conduct Standards which is implemented and enforced through TCM’s Code of Ethics.
Self-Directed Brokerage Accounts
A Self-Directed Brokerage Account (“SDBA”) is a brokerage window that allows participants to select
investment options outside of their employer’s core offerings while staying within the plan and receiving
the associated tax benefits. SDBAs provide more flexibility and control, enabling diversified, targeted and
strategic retirement investing. The SDBA is for investors who acknowledge and understand the risks
associated with many of the investments contained in the SDBA. Your IAR will work with you to identify
your investment goals and objectives, as well as risk tolerance, in order to create a portfolio allocation
designed to meet your objectives while staying within any plan specific restrictions.
Advisory accounts typically involve the purchase and/or sale of securities. These accounts are managed
on a discretionary or non-discretionary basis based on the plan and the participant’s needs.
Many SDBAs prohibit the following:
• Selling short or using margin
• Trading in foreign securities (stocks, bonds)
• Trading in bulletin board or pink sheet stocks
• Trading real estate/property outside of approved REITs
• Trading currencies
• Trading limited partnerships
• Trading futures/commodities
• Trading promissory notes
• Trading collectibles
• Trading municipal bonds
Financial Planning Services
Financial advisory services provided by TCM will include the analysis of your financial situation and
assistance in identifying and implementing appropriate financial planning and investment management
techniques to help you meet your specific financial goals and objectives. Such services will include a
written financial analysis and specific or general investment and/or planning recommendations. In
preparing your financial plan, TCM may address five areas of financial planning. These include financial
planning, money management, tax, estate and insurance planning.
Our specific services in preparing your plan may include:
• Review and clarification of your financial goals and objectives.
• Assessment of your overall financial position including cash flow, balance sheet, investment
strategy, risk management, and estate planning.
• Creation of a unique plan for each goal you have including personal and business real estate,
education, retirement or financial independence, charitable giving, estate planning, business
succession, and other personal goals.
• Development of a goal-oriented investment plan around tax suggestions, asset allocation,
expenses, risk, and liquidity factors for each goal. This includes IRA and qualified plans, as well
as taxable and trust accounts that require special attention.
• Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and
transfer, including liquidity as well as various insurance and possible company benefits.
• Crafting and implementation of, in conjunction with your estate and/or corporate attorneys as a
tax advisor, an estate plan to provide for you and/or your heirs in the event of an incapacity or
death.
• Generation of a benefits plan, risk management plan, and succession plan for your business, if
applicable.
Should you choose to implement the recommendations contained in the plan, TCM suggests that you work
closely with your attorney, accountant, insurance agent, and IAR/stockbroker. Implementation of financial
plan recommendations is entirely at your discretion.
Consulting Services
TCM also provides clients investment advice on a more limited basis in one or more isolated areas of
concern such as estate planning, real estate, retirement planning, or any other specific topic. Additionally,
TCM may provide advice on non-securities matters in connection with the rendering of estate planning,
insurance, real estate, and/or annuity advice. In these instances, you may be required to select your own
investment managers, broker-dealer, and/or insurance companies for the implementation of consulting
recommendations. If your needs include brokerage and/or other financial services, TCM may recommend
the use of one of several investment managers, brokers, banks, custodians, insurance companies, or other
FPs. You must independently evaluate these firms before opening an account or transacting business and
have the right to affect business through any firm you choose. You are under no obligation to follow the
consulting advice that TCM provides.
Wrap Fee Programs
TCM’s portfolio management services utilize a wrap fee program. Wrap fee programs allow the client
to pay a comprehensive fee for management, brokerage, clearing, custody, and administrative services.
TCM will receive a portion of the wrap fee for its services.
Assets
As of March 14, 2024, TCM has $421,132,382 in discretionary assets under management. TCM does
not have any non-discretionary assets under management.