A. Description of the Advisory Firm
TrinityPoint Wealth, LLC (“TrinityPoint” or “the Firm”) is an SEC registered investment adviser.
TrinityPoint’s registration as an investment adviser does not imply a certain level of skill or training.
The oral and written communications we provide to you, including this Brochure, is information that you
should use in your decision to hire us or continue a professional relationship with us. This Brochure provides
information about our qualifications and business practices.
TrinityPoint is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically,
TrinityPoint is a wholly-owned indirect subsidiary of Focus LLC. Ferdinand FFP Acquisition, LLC is the
sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board
of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and
collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment
vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because
TrinityPoint is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment
vehicles are indirect owners of TrinityPoint.
Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance
firms, business managers and other firms (the “Focus Partners”), most of which provide wealth
management, benefit consulting and investment consulting services to individuals, families, employers, and
institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment
companies as disclosed on their respective Form ADVs.
We help our clients obtain certain insurance solutions from unaffiliated, third-party insurance brokers by
introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our
parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of these
services and other important information.
TrinityPoint Wealth is managed by James Betzig, pursuant to a management agreement between TPW
Mgmt. Co., LLC and TrinityPoint Wealth. Mr. Betzig serves as an officer of TrinityPoint Wealth and is
responsible for the management, supervision and oversight of TrinityPoint Wealth.
B. Types of Advisory Services
TrinityPoint Wealth provides holistic and personalized financial planning and discretionary and non-
discretionary investment advisory services to individuals, including high net worth individuals, and entities,
including, but not limited to, family offices, trusts, estates, private foundations, and qualified retirement
plans.
Financial Planning and Consulting Services
TrinityPoint Wealth provides a variety of basic and comprehensive financial planning and consulting
services to clients. Such engagements generally are part of the investment advisory engagement or pursuant
to a separate engagement. Generally, such financial planning services will involve preparing a financial
plan or rendering a financial consultation based on the client’s financial goals and objectives. This planning
or consulting may encompass one or more areas of need, including, but not limited to, cash flow analysis,
investment planning, retirement planning, estate planning, personal savings, educational savings, and other
areas of a client’s financial situation.
A financial plan developed for or financial consultation rendered to the client will typically include general
recommendations for a course of activity, specific actions to be taken by the client, or both. For example,
recommendations may be made that the client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs. TrinityPoint Wealth
may recommend the services of itself and/or other professionals to implement its recommendations. Clients
are advised that a conflict of interest exists if, pursuant to a separate financial consultation agreement,
TrinityPoint Wealth recommends its own services, as such a recommendation would increase the advisory
fees paid to TrinityPoint Wealth. The client is under no obligation to act upon any of the recommendations
made by TrinityPoint Wealth, under a financial planning or consulting engagement, to engage the services
of any such recommended professional, including TrinityPoint Wealth itself.
Investment Management Services
In designing and implementing customized models and portfolio strategies, TrinityPoint Wealth can
manage, on a discretionary or non-discretionary basis, a broad range of investment strategies and vehicles.
TrinityPoint Wealth primarily allocates client assets among various mutual funds, exchange-traded funds
(“ETFs”), and individual debt and equity securities in accordance with clients’ stated investment objectives.
TrinityPoint Wealth may further recommend to clients that all or a portion of their investment portfolio be
managed on a discretionary basis by one or more unaffiliated money managers or investment platforms
(“External Managers”). The client may be required to enter into a separate agreement with the External
Manager(s), which will set forth the terms and conditions of the client’s engagement of the External
Manager. TrinityPoint Wealth generally renders services to the client relative to the discretionary selection
of External Managers. TrinityPoint Wealth also assists in establishing the client’s investment objectives
for the assets managed by External Managers, monitors and reviews the account performance and defines
any restrictions on the account. The investment management fees charged by the designated External
Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the
client’s assets, are exclusive of, and in addition to, the annual advisory fee charged by TrinityPoint Wealth.
When Adviser provides investment advice to you regarding your retirement plan account or individual
retirement account, 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. The way Adviser makes money creates some conflicts with your interests, so Adviser operates
under a special rule that requires Adviser to act in your best interest and not put our interest ahead of yours.
As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by
the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by
contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under
the federal and state securities laws or as a waiver of any unwaivable rights you possess.
Non-Purpose Loans
Where clients deem beneficial and appropriate based on their risk tolerance and investment objectives, a
non-purpose loan will be utilized as part of their financial planning strategy. A non-purpose loan is a type
of loan that uses an investment portfolio as loan collateral and the proceeds of which cannot be used to
purchase, carry or trade securities. This type of loan allows investors access to funds without having to sell
their investments. The proceeds of non-purpose loans may be deployed for a variety of for personal uses,
such as for education, real estate, taxes or other expenses. Such loans, using a client portfolio as collateral,
are high risk, and suitability will depend on other client assets and the client’s risk profile.
ERISA Services
TrinityPoint Wealth provides discretionary and non-discretionary, fiduciary and non-fiduciary advisory
services to the sponsors of the defined contribution, defined benefits and non-qualified deferred
compensation plans, who have ultimate authority to direct the investing and reinvesting of plan assets as
they deem appropriate, considering each plan’s stated objective, liquidity needs, and stated policies and
guidelines. Providing non-discretionary investment services to an ERISA plan means that the ERISA plan
client retains and exercises the final decision-making authority for implementing or rejecting TrinityPoint
Wealth’s recommendations. Providing discretionary investment management services as an ERISA 3(38)
investment manager means TrinityPoint Wealth makes the investment decisions in its sole discretion,
without the ERISA plan client’s prior approval. Certain of the foregoing services are provided by
TrinityPoint Wealth as a fiduciary under the Employee Retirement Income Security Act of 1974, as
amended (“ERISA”). To the extent a client’s plan is covered by ERISA, in accordance with ERISA Section
408(b)(2), each plan sponsor is provided with a written description of TrinityPoint Wealth’s fiduciary
status, the specific services to be rendered and all direct and indirect compensation TrinityPoint Wealth
reasonably expects under the engagement. When TrinityPoint Wealth provides investment advice for a fee
to an ERISA plan or ERISA plan participant, it is a fiduciary under ERISA.
TrinityPoint Wealth is a fiduciary under the Employee Retirement Income Security Act of 1974, as
amended (“ERISA”) with respect to investment management services and investment advice provided to
ERISA plans and ERISA plan participants. TrinityPoint Wealth is also a fiduciary under section 4975 of
the Internal Revenue Code of 1986, as amended (the “IRC”) with respect to investment management
services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and
ERISA plan participants. As such, TrinityPoint Wealth is subject to specific duties and obligations under
ERISA and the IRC, as applicable, that include, among other things, prohibited transaction rules which are
intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice, the
fiduciary must either avoid certain conflicts of interest or rely upon an applicable prohibited transaction
exemption (a “PTE”).
Health Savings Account Management
TrinityPoint Wealth offers investment advisory services for client Health Savings Accounts (“HSAs”) to
assist clients in investing HSA assets among mutual fund investment options, which will be reviewed every
six months. TrinityPoint Wealth utilizes the Health Savings Administrators platform to provide an
investment only HSA vehicle, and Health Savings Administrators comes with a collection of educational
tools. TrinityPoint Wealth will be paid a negotiated flat-dollar advisory fee directly from the HSA account.
TrinityPoint Wealth will monitor the client’s account and make investment recommendations based on the
client’s responses to a web-based interactive questionnaire that establishes a risk profile based on client
goals, objectives, time horizon and circumstances.
We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial
institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates,
“UPTIQ”) and Flourish Financial LLC (“Flourish”). Please see Items 5 and 10 for a fuller discussion of
these services and other important information.
C. Client-Tailored Advisory Services
TrinityPoint Wealth provides portfolio management services using investment models designed to meet a
variety of client investment objectives. Client portfolios are managed on the basis of individual clients’
financial situation and investment objectives. Clients may impose reasonable restrictions on the
management of their accounts if TrinityPoint Wealth determines, in its sole discretion, that the conditions
would not materially impact the performance of a management strategy or prove overly burdensome for
TrinityPoint Wealth’s management efforts.
D. Assets Under Management
As of the date of this filing, TrinityPoint Wealth has approximately $1,416,975,703 under management, of
which $1,278,725,379 is discretionary, and $138,250,324 is non-discretionary. The firm also has assets
under advisement of $16,843,522.