A. Firm Information
Transcend Capital Advisors, LLC (“Transcend” or the “Firm”) is a registered investment advisor with the U.S. Securities and
Exchange Commission (“SEC”). The Firm is organized as a Limited Liability Company under the laws of the State of Delaware.
The Firm was founded in October 2018. Transcend is a wholly owned subsidiary of Transcend Wealth Collective Holdings, LLC.
If you have any questions about the content of this Disclosure Brochure, please contact our Chief Compliance Officer (“CCO”),
Robert J. Bragoli, at (973) 646-2250 or by email at
rbragoli@transcendcapital.com.
B. Advisory Services Offered
Transcend 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, retirement plans and profit-sharing plans, and private foundations. Additionally, Transcend provides portfolio
management services to pooled investment vehicles. Each is herein referred to as a “client”.
Transcend serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Firm upholds
a duty of loyalty, fairness and good faith towards each client and seeks to mitigate conflicts of interest. Our fiduciary
commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see Item 11
– Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.
Investment Management Services
In designing and implementing customized models and portfolio strategies, Transcend can manage, on a discretionary or non-
discretionary basis, a broad range of investment strategies and vehicles, primarily as the sponsor and manager of the Transcend
Wrap Fee Program (the “Transcend Wrap Fee Program”), an arrangement where the client pays a fee (the “Program Fee”)
based on a percentage of the client’s assets under management, for Transcend’s investment advice, custody and commissions
for securities transactions executed at a designated custodian. Transcend primarily allocates client assets among various
individual debt and equity securities, mutual funds, exchange-traded funds (“ETFs”), structured products, options, and
alternative investments in accordance with clients’ stated investment objectives, risk profile and financial condition.
In addition, Transcend may also recommend that certain clients who qualify as accredited investors, as defined by Rule 501 of
the Securities Act of 1933, and a “qualified purchaser” as that term is defined in Section 2(a)(51)(A) of the Investment Company
Act of 1940, invest in affiliated and/or unaffiliated privately placed securities, which may include debt, equity and/or interests
in pooled investment vehicles (e.g., hedge funds). Investing in affiliated products present a conflict of interest as management
persons stand to benefit financially from additional revenue. Clients will be provided with a conflict disclosure statement.
Additionally, clients are under no obligation to invest in affiliated private products.
Transcend will select, recommend and/or retain mutual funds on a fund-by-fund basis. Due to specific custodial and/or mutual
fund company constraints, material tax considerations, and/or systematic investment plans, the Firm will select, recommend
and/or retain a mutual fund share class that does not have trading costs, but do have higher internal expense ratios than
institutional share classes. Transcend will seek to select the lowest cost share class available that is in the best interest of each
client and will ensure the selection aligns with the client’s financial objectives and stated investment guidelines.
Retirement Accounts – When Transcend and its advisors (“Advisory Persons”) provides investment advice to Clients regarding
ERISA retirement accounts or individual retirement accounts (“IRAs”), Transcend and its Advisory Persons are fiduciaries within
the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as
applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, Transcend will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an
IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA,
or from one type of account to another account (e.g. commission-based account to fee-based account). Such a
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recommendation creates a conflict of interest if Transcend will earn a new (or increase its current) advisory fee as a result of
the transaction. No client is under any obligation to roll over a retirement account to an account managed by Transcend.
Use of Independent Managers – Transcend may recommend to clients that all or a portion of their investment portfolio be
implemented by utilizing one or more unaffiliated money managers or investment platforms (collectively “Independent
Managers”). Independent Managers may be sourced directly or accessed through an investment management platform or
directly engaged by Transcend. The client will be required to enter into a separate agreement with the Independent
Manager[s]. Please see Item 10 – Other Financial Industry Activities and Affiliations for additional information.
Transcend serves as the client’s primary advisor and relationship manager. However, the Independent Manager[s] will assume
discretionary authority for the day-to-day investment management of those assets placed in their control. Transcend will assist
and advise the client in establishing investment objectives for their account[s], the selection of the Independent Manager[s],
and defining any restrictions on the account[s]. Transcend will continue to provide oversight of the client’s account[s] and
ongoing monitoring of the activities of these unaffiliated parties. The Independent Manager[s] will implement the selected
investment strategies based on their investment mandates. The client may be able to impose reasonable investment
restrictions on these accounts, subject to the acceptance of these third parties. Transcend does not receive any compensation
from these Independent Managers, other than its investment advisory fee, as described in Item 5 below.
All client assets will be managed within their designated account[s] at the custodian, pursuant to the terms of the investment
advisory agreement. Please see Item 12 – Brokerage Practices.
Private Fund Advisor Services
Transcend also provides portfolio management services to pooled investment vehicles (each a “Fund” and collectively the
“Funds”). These services are detailed in the offering documents for each Fund, which include as applicable, operating
agreements, private placement memoranda and/or term sheets, limited partnership agreements, separate disclosure
documents, and all amendments thereto (“Offering Documents”). Affiliates of Transcend serve as the General Partners of the
Funds (the “General Partners”). Each of the General
Partners is a related person of Transcend and is under common control
with Transcend. Please refer to Item 10 for additional information about the General Partners.
Transcend manages each Fund based on the investment objectives, policies and guidelines as set forth in the respective
Offering Documents and not in accordance with the individual needs or objectives of any particular investor therein. Each
prospective investor interested in investing in a Fund is required to complete a subscription agreement in which the prospective
investor attests as to whether or not such prospective investor meets the qualifications to invest in the Fund and further
acknowledges and accepts the various risk factors associated with such an investment.
Transcend could make affiliated private investment funds available to non-clients. Non-Transcend clients will not receive any
initial or ongoing personal investment advice or monitoring from Transcend relative to any such fund, including the suitability
of the fund for the non-client investor relative to the investor’s existing financial situation and portfolio. Although the non-
client investor will be subject to all fees and expenses assessed at the fund level, such investor will not be subject to the separate
Transcend investment advisory fee payable by Transcend clients. A Transcend client could potentially invest in an affiliated
private fund independent of Transcend’s personalized investment advisory services, but would not receive any initial or ongoing
advisory, monitoring or reporting services from Transcend relative to the fund. No Transcend client is under any obligation to
invest in any Transcend affiliated private investment fund.
For more detailed information on investment objectives, policies, and guidelines, please refer to the respective Fund’s
Offering Documents.
Financial Planning and Consulting Services
Transcend will typically provide a variety of comprehensive financial planning and consulting services to clients. Such
engagements may be part of the investment management services 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
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financial goals and objectives. This planning or consulting will 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 or specific actions to be taken by the client. For example, recommendations may be made that the client
start or revise their investment programs, commence or alter retirement savings, or establish education savings and/or
charitable giving programs. Transcend may recommend the services of itself and/or other professionals to implement its
recommendations. Clients are advised that a conflict of interest exists if Transcend recommends its own services, as such a
recommendation will increase the advisory fees paid to Transcend. The client is under no obligation to act upon any of the
recommendations made by Transcend under a financial planning or consulting engagement to engage the services of any such
recommended professional, including Transcend itself.
Retirement Plan Advisory Services
Transcend provides discretionary and fiduciary advisory services to the sponsors of the defined contribution, defined benefit
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 discretionary investment services to plans under the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”) means that the ERISA plan client retains and exercises the final decision-making authority for implementing or
rejecting Transcend’s recommendations. Certain of the foregoing services are provided by Transcend as a fiduciary. 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 Transcend fiduciary status, the specific services to be rendered and all direct and indirect compensation
Transcend reasonably expects under the engagement. When Transcend provides investment advice for a fee to an ERISA plan
or ERISA plan participant, it is a fiduciary under ERISA. In addition, Transcend is a fiduciary under the Internal Revenue Code
when it provides investment advice to an ERISA plan, ERISA plan participant, an IRA or an IRA owner (collectively, a “Retirement
Account Client”). Transcend is subject to specific duties and obligations under ERISA and the Internal Revenue Code that
include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from engaging in specified
conflicts of interest.
C. Client Account Management
Financial counsel and investment advice is customized and tailored to the unique goals, objectives and needs of each client.
The planning process begins with an in-depth discovery of the client’s goals, objectives, and attitudes. The goals and objectives
for each client are documented in writing and approved by the client. The stated goals and objectives for each client are
reflected in the client’s overall recommended financial and investment program and advice that Transcend provides on an
ongoing basis.
D. Wrap Fee Programs
As noted above, Transcend is the sponsor and manager of the Transcend Wrap Fee Program. When deemed to be in the client’s
best interest, Transcend includes securities transaction fees together with its investment advisory fees. Including these fees
into a single asset-based fee is considered a “Wrap Fee Program”. Transcend customizes its investment management services
for its clients. Transcend sponsors the Transcend Wrap Fee Program solely as a supplemental disclosure regarding the
combination of fees, which in addition to securities transaction fees, includes custodial costs, certain mutual fund redemption
fees, SEC exchange process fees, administrative fees, trade away transactions, and other fees and expenses (herein “Covered
Costs”) together with its investment advisory fees. Depending on the level of trading required for the client’s account[s] in a
particular year, clients may pay a higher or lower aggregate fee than if investment management and brokerage services were
purchased separately.
Please see Appendix 1 of Transcend’s Disclosure Brochure, which may be requested by calling Robert Bragoli, at (973) 646-2250
or by email
at rbragoli@transcendcapital.com.
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E. Assets Under Management
As of February 29, 2024, Transcend manages $2,857,163,070 in client assets, $2,824,626,620 of which are managed on a
discretionary basis and $32,536,450 on a non-discretionary basis. Clients may request more current information at any time
by contacting the Firm.