Description of Advisory Firm
Merit Wealth Management, LLC (“Merit” the “Firm,” “we,” “our,” or “us”) is a privately owned limited
liability company headquartered in Franklin, TN.
tru Independence Asset Management 2, LLC (“TIAM2”) has been registered as an investment adviser since
2020 and is owned by tru Independence, LLC. tru Independence, LLC, is a wholly owned subsidiary of Sanctuary
Wealth Group, LLC (“Sanctuary Wealth”).
As of December 31, 2023, TIAM2 managed approximately $543,886,653 in assets for approximately 1139
accounts on a discretionary basis and approximately $13,339,061 in assets for approximately 76 accounts on
a non-discretionary basis. In total, TIAM managed approximately $557,225,714 in assets for approximately
1215 accounts. approximately $196,458,902 for approximately 800 accounts are Wrap accounts.
As Merit is a new dba of TIAM2, there are no current assets managed by the Firm. While this brochure
generally describes the business of the Firm, certain sections also discuss the activities of its Supervised
Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status
or performing similar functions), employees, or any other person who provides investment advice on the
Firm’s behalf and is subject to the Firm’s supervision or control.
Advisory Services Offered
Merit offers discretionary and non-discretionary investment management, and investment advisory services
as well as financial planning and consulting. Prior to the Firm rendering any of the foregoing advisory services,
clients are required to enter into one or more written agreements with the Firm setting forth the relevant
terms and conditions of the advisory relationship (the “Advisory Agreement”).
Investment Management Services
The Firm offers continuous and regular investment supervisory services on a discretionary and non-
discretionary basis as well as financial planning and consulting. While we work with clients, we have the
ongoing responsibility to select and/or make recommendations based upon the objectives of the client, as
to specific securities or other investments that he/she recommends or purchases/sells in clients’
accounts. We utilize a variety of investment types when making investment recommendations/purchases
in client accounts which include, but are not limited to equity securities, fixed-income securities,
alternatives, mutual funds, and Independent Managers. The investments recommended/purchased are
based on the client’s individual needs, goals, and objectives. The Firm offers investment advice on any
investment held by the client at the start of the advisory relationship. We describe the material investment
risks under Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss. Financial Planning may be
provided to clients as a part of the Investment Management Services. When being provided as a separate
service it is described in this section under Financial Consulting Services below.
We discuss our discretionary authority below under Item 16 – Investment Discretion. For more
information about the restrictions clients can put on their accounts, see Tailored Services and Client
Imposed Restrictions in this item below. We describe the fees charged for investment management services
below under Item 5 – Fees and Compensation.
Financial Planning and Consulting
We offer financial planning services as a standalone service which typically involves providing a variety of
advisory services to clients regarding the management of their financial resources based on an analysis of their
individual needs. These services can range from broad-based financial planning to consultative or single-
subject planning. If you retain our firm for financial planning services, we will meet with you to gather
information about your financial circumstances and objectives. We may also use financial planning software
to determine your current financial position and to define and quantify your long-term goals and objectives.
Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term,
targeted objectives. Once we review and analyze the information you provide to our firm and the data derived
from our financial planning software, we will deliver a written plan to you, designed to help you achieve your
stated financial goals and objectives.
Financial plans are based on your financial situation at the time we present the plan to you, and on the financial
information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives,
or needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose to act on
any of our recommendations, you are not obligated to implement the financial plan through any of our other
investment advisory services. Moreover, you may act on our recommendations by placing securities
transactions with any brokerage firm.
We describe fees charged for Consultation Services below under Item 5 - Fees and Compensation.
Pension Consulting Services
We offer pension consulting services to employee benefit plans and their fiduciaries based on the needs of
the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may
include an existing plan review and analysis and education services to plan participants, investment
performance monitoring, and/or ongoing consulting. These pension consulting services will generally be
non-discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain
with the plan sponsor or other named fiduciary.
We may also assist with participant enrollment meetings and provide investment-related educational
seminars to plan participants on such topics as:
• Diversification;
• Asset allocation;
• Risk tolerance; and
• Time horizon
Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of pension consulting services to plans on an individually negotiated
basis. All services, whether discussed above or customized for the plan based upon requirements from the
plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a
written agreement and be consistent with the parameters set forth in the plan documents.
Either party to the pension consulting agreement may terminate the agreement upon written notice to the
other party in accordance with the terms of the agreement for services. The pension consulting fees will
be prorated for the quarter in which the termination notice is given, and any unearned fees will be refunded
to the client.
Additionally, we will offer the client assistance in setting up a relationship with a third-party administrator
and processing enrollment forms. Advice to plan participants will be limited to general, impersonal advice.
The scope of these services, the fees, and the terms of the agreement for these services will be negotiated
on a case-by-case basis with each client. We may be compensated on the basis of assets under
management, a fixed fee, an hourly fee, or a combination of fee arrangements based on the complexity of
the plan and the agreement with the client.
These accounts are regulated under the Employee Retirement Income Securities Act ("ERISA"). We will
provide consulting services to the client as described above; however, the client must make the ultimate
decision as to retaining the services of such investment advisers we may recommend. The client is free to
seek independent advice about the appropriateness of any recommended services for the plan.
Plan participants who wish to engage us for individualized planning or management services and fees may
do so by executing a separate agreement with our firm.
Use of Independent Managers and Sub-Advisors
The Firm may select certain Independent Managers and/or Sub-Advisors to actively manage a portion of
its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager
and/or Sub-Advisor may be set forth in a separate written agreement with the designated Independent
Managers engaged to manage their assets.
The Firm evaluates a variety of information about Independent Managers and/or Sub-Advisors, which may
include the Independent Managers’ and/or Sub-Advisors’ public disclosure documents, materials supplied
by the Independent Managers themselves, and other third-party analyses it believes are reputable. To the
extent possible, the Firm seeks to assess the Independent Manager’s and/or Sub-Advisor’s investment
strategies, past performance, and risk results concerning its clients’ individual portfolio allocations and risk
exposure. The Firm also takes into consideration each Independent Manager’s and/or Sub-Advisor’s
management style, returns, reputation, financial strength, reporting, pricing, and research capabilities,
among other factors.
The Firm continues to provide services relative to the discretionary selection of the Independent Managers
and/or Sub-Advisor. On an ongoing basis, the Firm monitors the performance of those accounts being
managed by Independent Managers. The Firm seeks to ensure the Independent Managers and/or Sub-
Advisor strategies and target allocations remain aligned with its client’s investment objectives and overall
best interests.
Other Third-Party Services
The Firm has entered into a service agreement with Pontera to provide asset management services for
accounts held away from our primary custodial affiliations. Through this, we are able to create a portfolio,
consisting of the securities/investment opportunities available depending on the type of held away account
being managed by our firm. The Pontera platform allows us to avoid being considered to have custody of
Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not
affiliated with the platform in any way and receive no compensation from them for using their platform. A
link will be provided to the Client allowing them to connect an account(s) to the platform. The client’s
individual investment strategy is tailored to their specific needs and may include some or all of the
securities made available. Portfolios will be designed to meet a particular investment goal, determined to
be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios
are continuously and regularly monitored, and if necessary, rebalanced.
Sponsor and Manager of Wrap Program
Merit does not currently participate in a wrap program.