A. Firm Information
True Wealth & Company LLC (“True Wealth” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (“LLC”) under the
laws of the State of Kansas. True Wealth was founded in 2012 and is owned and operated by Bryan Sarff and
Kenneth Burkhead III. This Disclosure Brochure provides information regarding the qualifications, business
practices, and the advisory services provided by True Wealth.
B. Advisory Services Offered
True Wealth offers investment advisory services to individuals, high net worth individuals, trusts, estates,
businesses, retirement plans, charitable organizations, corporations, and other business entities (each referred to
as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. True Wealth's fiduciary commitment is further described in the Advisor’s Code of Ethics. For
more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading.
Investment Management Services
True Wealth provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management and related advisory
services. True Wealth works closely with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create a portfolio strategy. True Wealth will then construct an investment
portfolio, consisting diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s
investment goals. The Advisor may also utilize individual stocks, bonds, options contracts, structured notes to meet
the needs of its Clients. The Advisor may retain certain types of investments based on a Client’s legacy
investments based on portfolio fit and/or tax considerations.
True Wealth’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. True Wealth will construct, implement and monitor the portfolio to ensure it meets the goals, objectives,
circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable
restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
True Wealth evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. True Wealth may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. True Wealth may recommend specific positions to increase sector or asset class weightings. The Advisor
may recommend employing cash positions as a possible hedge against market movement.
True Wealth may recommend selling positions for reasons that include, but are not limited to, harvesting capital
gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or
overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet
Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
True Wealth will provide investment management services and related services. True Wealth accepts custody of a
Client’s funds or securities, through the deduction of management fees from the Client’s account[s] at the
Custodian, and in certain situations where a Supervised Person of True Wealth may have access to a Client’s held-
away account login credentials.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary 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, the Advisor will
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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 recommendation creates a conflict of interest if the Advisor 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 the Advisor.
Participant Account Management: True Wealth offers qualified plan consulting services to individuals for a fee
based on included assets in their plan described in detail under “Fees and Compensation” section of this brochure.
True Wealth meet with the client for information gathering. True Wealth meets with the client at least annually or on
an as needed basis determined by the client to review the investment options available within the plan. True Wealth
will make investment recommendations to the client based on the investment options available and the client’s
financial objectives in a meeting
with the client.
Financial Planning Services
True Wealth will typically provide a variety of financial planning and consulting services to Clients, pursuant to a
written financial planning agreement. Services are offered in several areas of a Client’s financial situation,
depending on their goals and objectives. Generally, such financial planning services involve preparing a formal
financial plan or rendering a specific 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, investment
planning, retirement planning, personal savings, business retirement planning, education savings, insurance needs
and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually 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, establish education savings and/or charitable giving programs.
True Wealth may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may
not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date,
assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for
investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to
act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
Retirement Plan Advisory Services
True Wealth may provide the following retirement plan advisory services:
Employee Enrollment and Education Tracking
Investment Policy Statement (“IPS”) Support
Ongoing Investment Recommendation and Assistance
ERISA 404(c) Assistance
True Wealth may provide investment advisory services on behalf of the Plan and Plan Sponsor, which may be in
either a 3(21) or 3(38) context depending on whether or not the Advisor is also providing discretionary investment
management over the Plan assets. For 3(38) services, the Advisor shall have the discretion to select the
investments for the Plan and/or make investment decisions on behalf of Plan Participants.
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Business Consulting
We provide business consulting services to small business owners which includes wealth planning through us and
Professional Employer Organizations (“PEO”) through an affiliate, myTrueHR, LLC. We also coordinate with other
professionals for Accounting, Tax Planning, Legal Services, Commercial Banking and Insurance.
Seminars and Workshops
True Wealth holds seminars and workshops to educate the public on different types of investments and the
different services they offer. The seminars are educational in nature and no specific investment or tax advice is
given. True Wealth does not charge a fee for attendance of these seminars.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each client are documented in our client files. Investment strategies are created that
reflect the stated goals and objectives of each client. Clients may impose restrictions on investing in certain
securities or types of securities, subject to True Wealth agreement. Agreements may not be assigned without client
consent.
C. Client Account Management
Prior to engaging True Wealth to provide investment advisory services, each Client is required to enter into one or
more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor
and the Client. These services may include:
• Establishing an Investment Strategy – True Wealth, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – True Wealth will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – True Wealth will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
• Investment Management and Supervision – True Wealth will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
True Wealth does not manage or place Client assets into a wrap fee program. Investment management services
are provided directly by True Wealth.
E. Assets Under Management
As of December 31, 2022, True Wealth manages $126,496,448 in Client assets, $122,072,201 of which are
managed on a discretionary basis and $4,424,247 on a non-discretionary basis. Clients may request more current
information at any time by contacting the Advisor.