TMD is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, TMD
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 TMD is an indirect, wholly-owned subsidiary of Focus LLC,
CD&R and Stone Point investment vehicles are indirect owners of TMD.
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.
TMD is managed primarily by Todd Douma and Gavin Lyons pursuant to a management
agreement between WM Partner Services, LLC (“WMPS”) and TMD. Mr. Douma and Gavin
Lyons serve as the officers of TMD and, in that capacity, are responsible for the management,
supervision and oversight of TMD.
While this brochure generally describes the business of TMD, certain sections also discuss the
activities of its personnel, including its officers, partners, directors (or other persons occupying a
similar status or performing similar functions), employees or any other person who provides
investment advice on behalf of TMD and is subject to the Firm’s supervision or control (each, a
“Supervised Person”).
In addition to the advisory services described in this brochure, TMD, under the d.b.a. CuraFin
Advisors, provides investment advisory and related services to retirement plans subject to the
provisions of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”)
(“Plan Client” or “Plan”). While the services provided to Plan Clients are described below, TMD
maintains and delivers to most Plan Clients a different brochure tailored specifically to the
provision of investment advisory and related services to Plan Clients under the CuraFin Advisors
d.b.a. However, for a limited number of Plan Clients advisory services are delivered without the
utilization of the CuraFin d.b.a.
Types of Advisory Services Offered
Wealth Management and Investment Management Services
TMD provides wealth management and discretionary and non-discretionary investment
management services. TMD allocates client assets among various, no-load and load-waived
mutual funds, exchange-traded funds (“ETFs”), individual securities, third party managers, and
various alternative investment managers/private funds.
TMD tailors its advisory services to accommodate the needs of its individual clients and
continually seeks to manage its clients’ portfolios in a manner consistent with their specific
investment profiles. Clients are advised to promptly notify TMD if any changes occur in their
financial situation or if they wish to place any limitations on the management of their portfolios.
Clients may request reasonable restrictions on the management of their accounts if TMD
determines, in its sole discretion, the conditions will not materially impact the performance of a
portfolio strategy.
In providing wealth management and investment management services TMD 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. TMD generally renders services to the client relative to the discretionary
selection of External Managers. TMD 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.
TMD implements investment advice on behalf of certain clients in held-away accounts that are
maintained at independent third-party custodians. These held-away accounts are often 401(k)
accounts, 529 plans and other assets that are not held at our primary custodian(s).
Limited Scope Financial Planning and Consulting Services
TMD may also provide one-time, non-discretionary topic-specific consultation and administrative
services regarding investment and/or other financially related needs of its clients. This may
include advice on limited-scope wealth management matters as well as non-traditional areas such
as business acquisition/sales or business operations. In general, these are consulting needs that
fall outside the scope of a client's financial plan.
Services Provided to Plan Clients
TMD provides discretionary investment management, non-discretionary investment management
and retirement plan consulting services to Plans. Each Plan Client will select the services to be
provided in writing as part of the investment fiduciary and retirement plan consulting agreement
("Retirement Plan Agreement"). TMD will provide specific investment advice to Plan Clients
regarding the selection of investment manager(s) and/or investment vehicles available to the Plan
within the platform provided by the Plan's custodian.
TMD may select or recommend, as described below, certain collective investment trust funds for
which TMD serves as a sub-adviser (the “Collective Funds”) that are further explained in Methods
of Analysis, Investment Strategies, Risk of Loss and Affiliations sections of this Brochure. When
TMD provides services to Plan Clients in the capacity as a fiduciary under ERISA, TMD does not
receive any fees from the Collective
Funds. The only fees received are those specified in the
Retirement Plan Agreement.
TMD may also provide administrative support, service provider support, investment monitoring
support and participant services as described in the Retirement Plan Agreement, as applicable.
Discretionary Investment Management Services for Plan Clients
TMD will provide discretionary investment management services to certain Plan Clients as a
fiduciary under Section 3(38) of ERISA and thus will serve as an "investment manager" pursuant
thereto. Upon reviewing the investment objectives, risk tolerance and goals of the Plan Client set
forth in the Plan's investment policy statement ("IPS"), the sponsor of each Plan Client (the "Plan
Sponsor") will determine which of the following discretionary services, if any, TMD will provide to
the Plan Client: (a) the selection, monitoring and replacement of designated investment
alternatives, (b) the creation and maintenance of model asset allocation portfolios, and/or (c) the
selection, monitoring and replacement of qualified default investment alternatives.
Non-Discretionary Investment Management Services for Plan Clients
TMD will also provide non-discretionary investment management services to certain Plan Clients,
serving as a "fiduciary" as defined by Section 3(21) of ERISA. After reviewing the investment
objectives, risk tolerance and goals of the plan set forth in the Plan's IPS, TMD will make
recommendations to the Plan Sponsor, but the Plan Sponsor will ultimately be responsible for
implementing those recommendations. If the Plan does not have an IPS, TMD may provide
recommendations to the Plan Sponsor to assist it in establishing an IPS. If the Plan has an existing
IPS, TMD will review it for consistency with the Plan's objectives. If the IPS does not represent
the objectives of the Plan based on TMD’s understanding of the objectives, TMD will recommend
revisions to align the IPS with the Plan's objectives. The Plan Sponsor of each Plan Client will
determine which of the following services, if any, TMD will provide to the Plan Client: (a) advice
on designated investment alternatives, (b) advice on model asset allocation portfolios, and/or (c)
advice on qualified default investment alternatives.
Retirement Plan Consulting Services
TMD will also provide retirement plan consulting services designed to assist the Plan Sponsor in
meeting his or her fiduciary duties to administer the Plan in the best interest of the Plan's
participants and their beneficiaries. Such services are not fiduciary services under ERISA. The
Plan Sponsor of each Plan Client receiving consulting services will determine which of the
following services TMD will provide to the Plan Client: (a) administrative support, (b) oversight of
relationships with the Plan's service providers, (c) investment monitoring support, and/or (d)
participant services.
TMD As an ERISA Fiduciary
TMD is a fiduciary under ERISA with respect to investment management services and investment
advice provided to ERISA plan clients, including ERISA plan participants. TMD is also a fiduciary
under section 4975 of the Internal Revenue Code (the “IRC”) with respect to investment
management services and investment advice provided to ERISA plans, ERISA plan participants,
IRAs and IRA owners (collectively, “Retirement Account Clients”). As such, TMD is subject to
specific duties and obligations under ERISA and the IRC 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 in which it has a conflict of interest, the fiduciary must
either avoid or eliminate the conflict or rely upon a prohibited transaction exemption (a “PTE”).
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.
Donor Advised Fund Services
Certain TMD clients will establish donor advised funds through various third-party charitable
programs which funds will be managed in accordance with the specific investment policies and
guidelines of the applicable charitable platform. Clients will establish a donor advised account,
transfer funds earmarked for charitable donation and recognize a tax deduction in the year that
funds are transferred into an account opened on a charitable platform. The funds remain in such
account until the Client designates a charity, an amount and a date to donate to such charity.
Under independent advisor programs established within each Charitable Platform, donors
nominate an independent investment adviser, including TMD, to manage accounts established
on the Charitable Platforms. If nominated, TMD will manage the donor’s account pursuant to
investment guidelines established by each Charitable Platform.
UPTIQ Treasury and Credit Solutions
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”). Please see Items 5 and 10 for a fuller discussion of these services
and other important information.
Focus Risk Solutions
TMD helps 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.
Assets Under Management
As of December 31, 2023, TMD has $978,051,000 in discretionary assets and $8,341,000 in
non-discretionary assets under management. These assets under management include the
advisory assets of Plan Clients receiving advisory services under the CuraFin Advisors d.b.a.