Firm Description
Trinity Legacy Partners, LLC, hereinafter (“the Adviser”) was founded in 2011. The adviser is
registered with the Securities and Exchange Commission (“SEC”).
As an Investment Adviser, we must adhere to a fiduciary standard. This standard requires
Advisers to act and serve a client’s best interests with the intent to eliminate, or at least to
expose, all potential conflicts of interest which might incline an Adviser consciously or
unconsciously to render advice which is not in the best interest of the client.
The Adviser is a fee-only investment management and financial planning firm. The firm does not
sell securities on a commission basis. The firm is not affiliated with entities that sell financial
products or securities.
The Adviser does not act as a custodian of client assets and the client always maintains asset
control.
The Adviser has the discretion to manage client accounts as outlined in the firm’s investment
adviser agreement.
Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by
the client on an as-needed basis. Any conflicts of interest arising out of the Adviser’s, or its
associated persons are disclosed in this brochure.
Principal Owners: Principal Owners: John P. Wilkinson, III; POM Asset Management, L.P.,
Lifetree Financial, LLC, Anthony L. Garcia, and John J. Hunter are all principal owners.
Additional Office - by appointment:
2001 Timberloch Place, #500
The Woodlands, TX 77380
Types of Advisory Services
The Adviser provides investment supervisory services, also known as asset management
services, and furnishes investment advice through consultations.
The Adviser will provide asset management services and is compensated for such services
through a management fee further outlined below in Item 5. It should be noted that important
aspects of the client’s financial affairs are reviewed prior to executing and implementing any
investment management services.
Investments may include equities (stocks), commercial paper, certificates of deposit, municipal
securities, mutual funds shares, exchange-traded fund shares (ETFs), U. S. government
securities, and options contracts.
The Adviser also provides financial planning and consulting. Generally, such consultations and
planning may include and but are not limited to any of the following: reviewing investment
accounts and asset allocation; strategic tax planning; reviewing retirement accounts and
employer retirement plans; reviewing insurance policies; developing retirement scenarios; estate
planning review; and college education planning.
Non-Charles Schwab Accounts
The Adviser uses a third-party platform to facilitate management of brokerage accounts and
defined contribution plan participant accounts, with discretion. The Adviser manages these
accounts using the Pontera Order Management System. Please refer to Item 12 – Brokerage
Practices for more information.
DOL Disclosure
When the Adviser provides investment advice to clients regarding a client’s retirement plan
account or individual retirement account, the Adviser is a fiduciary 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. 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.
Assets Under Management
As of December 31, 2023, the Adviser managed approximately $379,881,141 of assets under
management, which included $352,134,700 on a discretionary basis and $27,676,441 on a non-
discretionary basis.
Tailored Relationships
The goals and objectives for each client are documented. Clients may impose restrictions on
investing in certain securities or types of securities.
Assignment
of Investment Management Agreements
Agreements may not be assigned without the written consent of the client.
Types of Agreements
The following agreements define the typical client relationships.
Investment Advisory Agreement
As part of the investment management service, important aspects of the client’s financial affairs
are reviewed, and realistic and measurable goals are set and objectives to reach those goals are
defined. As goals and objectives change over time, suggestions are made and implemented on an
ongoing basis. The Adviser periodically reviews a client’s financial situation and portfolio
through regular contact with the client, which often includes an annual meeting with the client.
The Adviser makes use of portfolio rebalancing software to maintain client allocations according
to the Investment Objective Statement in effect.
The scope of work and fee for an Advisory Service Agreement is provided to the client in
writing prior to the start of the relationship. The agreement sets forth the services to be provided,
the fees for the service and the agreement may be terminated by either party in writing at any
time.
Investment Consulting Agreement
The Adviser may consult with a client on assets held in employer-sponsored retirement plans,
such as 401(k) plans. The Adviser can review the investment options in such a retirement plan
and recommend an asset allocation, based upon a client’s investment objective. As part of this
agreement, the Adviser periodically reviews a client’s retirement portfolio.
With regard to retirement plans that are subject to the Employee Retirement Income Security Act
of 1974 (“ERISA”), the Adviser generally assumes the role of a fiduciary with respect to such
ERISA plans. Additionally, the Responsible Plan Fiduciary for ERISA plans will be provided
with an ERISA Fee and Services Disclosure pursuant to Section 408(b)(2) of ERISA, prior to the
ERISA Plan engaging the Adviser for advisory services.
Financial Planning Agreement
A financial planning analysis may include but is not limited to: net worth statement; cash flow
statement; review of investment accounts, asset allocation analysis; strategic tax planning;
review of retirement accounts; review of insurance policies, evaluation of retirement goals; estate
planning review; and college education planning.
Financial planning may be the only service provided to the client and it does not require the
client to use or purchase the investment advisory services offered by the Adviser. The Adviser
may receive compensation for financial planning and providing investment consulting services.
The Adviser does not make any representation regarding products that may be referenced in a
financial plan and the client is under no obligation to accept the recommendations of the Adviser
or use the services of the Adviser in particular.
Asset Management
Investments may also include equities (stocks), warrants, corporate debt securities, commercial
paper, certificates of deposit, municipal securities, investment company securities and mutual
funds shares, exchange-traded fund shares (ETFs), U. S. government securities, options
contracts, futures contracts, and interests in partnerships.
Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The
brokerage firm charges a fee for stock and bond trades. The Adviser does not receive any
compensation, in any form, from fund companies.
From time to time the Adviser may recommend public offerings (IPOs) if deemed suitable.
WRAP Program
The Adviser does not sponsor a WRAP fee program.
Termination of Agreement
A client may terminate any of the aforementioned agreements at any time by notifying the
Adviser in writing. Clients shall be charged pro-rata for services provided through to the date of
termination. If the client made an advance payment, the Adviser would refund any unearned
portion of the advance payment.
The Adviser reserves the right to terminate any financial planning engagement where a client has
willfully concealed or has refused to provide pertinent information about financial situations
when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice.
Any unused portion of fees collected in advance will be refunded.