We provide a wide array of advisory services to our clients in which both proprietary and non- proprietary investment options are made available. We may manage these advisory accounts on a discretionary and/or non-discretionary basis. We offer these services to individuals, pension and profit sharing plans, trusts, estates and/or charitable organizations and also corporations and/or other business entities. The Registrant participates in advisory programs as portfolio manager, advisor, co-advisor or solicitor depending on the program and depending on the needs or direction of its clients. Clients should discuss with their advisor what roles are appropriate, and what programs are appropriate for their investment objectives and risk tolerances. The Registrant also may select other investment advisors for its clients, in particular by advising clients regarding Independent Managers or Third Party Asset Management Programs ("TAMPs") or by referral arrangements. To the extent the Registrant utilizes an Independent Manager or a Third Party Money Manager, the Registrant shall provide the Independent Manager or Third Party Money Manager with each client's particular investment objective and risk tolerance. Any changes in the client's financial situation or investment objectives reported by the client to the Registrant shall be communicated to the Independent Manager or Third Party Money Manager within a reasonable period of time. Of the funds managed by and/or through the services provided by TFS Advisory Services, the majority are considered "Investment Supervisory Services" meaning we provide continuing advice as to the investment of funds on the basis of the individual needs of each client. These services will generally include the following types of asset management services: Individual Portfolio Management - we provide asset management of client funds based on the individual needs of the client. The Investment Advisor Representative initially determines the client's financial objectives, time horizons, restrictions, etc; develops the client's personal investment plan; then creates and manages a customized portfolio based on that plan. Model Portfolio Management - we provide portfolio management services to clients using model asset allocation portfolios. Each model portfolio is designed to meet a particular investment goal. The Investment Advisor Representative initially determines the client's financial objectives, time horizons, restrictions, etc; and determines if the model portfolio is suitable for the client. Once a suitable model is determined, the portfolio is managed based on the portfolio's goals, rather than on each client's individual needs. Third Party Money Managers - TFS Advisory Services does not directly manage these client assets. Each Investment Advisor Representative may outsource the management of client funds to an outside money manager who may utilize an investment strategy, which after discussions with the client, may be deemed the closest in line with the client's investment goals and objectives.
TFS Advisory Services is a SEC-registered investment advisor with its principal place of business located in Lincroft, New Jersey. TFS has been conducting advisory business since 1997, through TFS Advisory Services, a division of TFS Securities, Inc., a wholly owned subsidiary of Tomorrow's Financial Services, LLC, formerly known as Innovative Market Trends and TFS Portfolio Advisory Services. Tomorrow's Financial Services, LLC is a wholly owned subsidiary of WIA Holdings, Inc. Financial Planning and Consulting Services - financial planning is a comprehensive evaluation of a client's current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. We also provide on a limited basis advisory services that differentiates the level of services being provided to the client, reflecting that our management of client portfolios is not continuous and therefore is not "Investment Supervisory Services." These services typically are consultative in nature and are defined by the terms of the underlying contracts as such. Consultative advisory services typically have certain terms associated with the compensation for such services. These associated terms may generally include the following: Hourly Fees Flat - Fee for Service Retainer Fees Outside of the specific mention in the contract, these types of compensation tend to indicate that the advisory services provided are temporary in nature or based upon time spent with the client and not indicative of continuous and regular supervisory or management services. TFS Advisory Services offers these types of services but they represent a very small part of our advisory business. Third Party Asset Management Programs ("TAMPS") The Registrant participates in advisory programs as portfolio manager, advisor, co-advisor or solicitor depending on the program and depending on the needs or direction of its clients. Clients should discuss with their advisor what roles are appropriate, and what programs are appropriate for their investment objectives and risk tolerances. The Registrant also may select other investment advisors for its clients, in particular by advising clients regarding Independent Managers or Third Party Asset Management Programs ("TAMPs") or by choosing from available managers on the Envestnet Asset Mangement, Inc. ("Envestnet") platform. To the extent the Registrant utilizes an Independent Manager or a Third Party Money Manager, the Registrant shall provide the Independent Manager or Third Party Money Manager with each client's particular investment objective and risk tolerance. Any changes in the client's financial situation or investment objectives reported by the client to the Registrant shall be communicated to the Independent Manager or Third Party Money Manager within a reasonable period of time. The following provides in more detail, the full depth & breadth of the advisory services TFS Advisory Services offers to our clients: INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client's individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary and/or non-discretionary basis and offer both proprietary and non-proprietary alternatives to the client. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. We offer TFS Perspectives, an asset -based fee account with no commissions or transaction fees to the client. The client, or the investment advisor representative, depending on the agreement signed, may conduct transactions in a wide variety of securities and periodically adjust portfolio holdings as circumstances dictate - for a single asset-based fee. Clients from time to time may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. The firm may not be able to accommodate all requests. Our investment recommendations are limited to specific products or services offered by a broker-dealer or insurance company and will generally include advice regarding the following securities: Exchange-listed securities Securities traded over-the-counter Variable life insurance Variable annuities Mutual fund shares Corporate debt securities (other than commercial paper) Certificates of deposit Municipal securities US Government securities Interests in partnerships investing in real estate Exchanged Traded Funds Separately Managed Accounts Other Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability.
INVESTMENT SUPERVISORY SERVICES ("ISS") PROPRIETARY MODEL PORTFOLIO MANAGEMENT Our firm provides portfolio management services to clients using model asset allocation portfolios. Our clients have access to these models through our proprietary program branded as "Buy/Hold Plus". Each model portfolio is comprised of mutual funds and/or Exchanged Traded Funds and is designed to meet a specified range of risk tolerance and/or time horizon in connection with a client's broad based investment goals. Investments in our Traditional Buy/Hold Plus program are based on one of five models and combine traditional asset allocation with our proprietary manager selection process to determine the best performing fund within each asset class. Investments in our Buffered Buy/Hold Plus program utilize buffered or defined outcome ETFs to build portfolios that can prove upside potential to an index-based cap, while still maintaining a degree of downside protection. Managers are screened quarterly and portfolios are conditionally re-balanced according to predetermined allocations. The models and their respective allocations are as follows: Traditional Models: Conservative – 30% stock funds, 68% bond funds, 2% cash Moderately Conservative – 45% stock funds, 53% bond funds, 2% cash Moderate – 65% stock funds, 33% bond funds, 2% cash Moderately Aggressive – 75% stock funds, 23% bond funds, 2% cash Aggressive - 86% stock funds, 12% bond funds, 2% cash Buffered Models: Buffered 100 - 98% buffered ETFs, 2% cash Buffered 60 - 40% equity ETFs, 58% buffered ETFs, 2% cash These advisory accounts are managed on a discretionary basis. Through personal discussions with the client and the use of an investment policy statement questionnaire in which the client's goals and objectives are established, we determine if the model portfolio is suitable to the client's circumstances. Once we determine the suitability of the portfolio, the portfolio is managed based on the portfolio's goal, rather than on each client's individual needs. Clients do not have the opportunity to place reasonable restrictions on these types of investments held in their account. Clients retain individual ownership of all securities. Our investment recommendations are limited to the specific products or services offered by a broker dealer or insurance company and will generally include advice regarding the following securities: Exchange-listed securities Securities traded over-the-counter Mutual Funds Exchanged Traded Funds Variable Annuities Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, we will: 1. Periodically contact each participating client to determine whether there have been any changes in the client's financial situation or investment objectives; 2. Be reasonably available to consult with the client 3. Encourage clients to contact us immediately should there be a change of their financial situation; and 4. Maintain client suitability information in each client's file. In addition, each introducing investment advisor representative remains in close contact with their respective clients to update various financial information and determine continued suitability. INVESTMENT SUPERVISORY SERVICES ("ISS") NON PROPRIETARY MODEL PORTFOLIO MANAGEMENT Our individual advisory representatives may provide portfolio management services to clients using model asset allocation portfolios. These models may be managed to a specific portfolio goal. The individual advisory representatives manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Through personal discussions with the client in which the client's goals and objectives are established, the individual advisor representative determines if the model portfolio is suitable to the client's circumstances. Once they determine the suitability of the portfolio, the portfolio is managed based on the portfolio's goal, rather than on each client's individual needs. Clients, nevertheless, typically have the opportunity to place reasonable restrictions on the types of investments to be held in their account. Clients retain individual ownership of all securities. These investment recommendations are limited to the specific product or service offered by a broker dealer or insurance company and will generally include advice regarding the following securities: Exchange-listed securities Securities traded over-the-counter Mutual fund shares Exchanged Traded Funds Variable Annuities Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. In some cases, investment advisory representatives may incorporate alternative strategies designed to limit risk but also capture upside potential in both up and down markets. There is no assurance that these strategies will be successful or that any attempted performance goals will be achieved.
These strategies may include the use of exchange traded funds that offer leverage or that are designed to perform Inversely to the index or benchmark they track-or both. Our investment advisory representatives are sure to ascertain a client's suitability prior to the use of such instruments or trading strategies, based on a full understanding of the terms and features of the product or strategy recommended. Typically, such products are utilized in sophisticated trading strategies and are highly complex in nature and are disclosed to the clients of TFS Advisory Services as such. In addition, due to the effects of compounding, their performance over longer periods of time can differ significantly from their stated daily objective. Therefore, inverse and/or leveraged ETFs that are reset daily may not be suitable for retail investors who plan to hold them for longer than one trading session. To ensure that initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, we will: 1. Periodically send written reminders to each Model Portfolio Management Services client requesting any updated information regarding changes in the client's financial situation and investment objectives; 2. Periodically contact each participating client to determine whether there have been any changes in the client's financial situation or investment objectives, and whether the client wishes to impose investment restrictions or modify existing restrictions; 3. Be reasonably available to consult with the client 4. Encourage clients to contact us immediately should there be a change of their financial situation; and 5. Maintain client suitability information in each client's file. PENSION CONSULTING SERVICES We also provide several advisory

services separately or in combination. While the primary clients for these services will be pension, profit sharing and 401(k) plans, we offer these services, where appropriate, to individuals and trusts, estates and charitable organizations. Pension Consulting Services are comprised of an array of services. Clients may choose to use any or all of these services. TFS Advisory Services provides services to assist plan sponsors, plan trustees and investment committees to meet their ERISA fiduciary responsibilities. TFS Advisory Services provides these services under ERISA 3(21) AND ERISA 3(38). Under these sections, clients can engage TFS Advisory Services and / or a third party manager to provide investment advisory services. By doing so, TFS Advisory Services and / or the third party manager will share fiduciary responsibility with plan trustees and investment committees as it relates to the assets TFS Advisory Services is under agreement to provide investment management or advisory services. As part of a client’s fiduciary team, TFS Advisory Services provides the investment expertise to implement the plans investment policies and objectives.
TFS Advisory Services acting as an advisor under ERISA 3(21) For the purpose of ERISA 3(21), TFS Advisory Services does not exercise any discretionary authority or control respecting management of the plan or management or disposition of its assets or have any discretionary authority or discretionary responsibility in the administration of the plan. Therefore, TFS Advisory Services is not a "fiduciary", pursuant to ERISA except to the extent it renders "investment advice" to the plan within the meaning of section 3(21) of ERISA and Department of Labor regulations there under. The participants are responsible for any individual investment selections made under the plan. Under ERISA 3(21), TFS Advisory Services acts as the advisor making investment recommendations, but it is ultimately up to the plan sponsor to decide whether and how to implement these recommendations. Furthermore, under ERISA 3(21), the participants are responsible for any individual investment selections made under the plan. TFS Advisory Services acting as an advisor under ERISA 3(38) For the purpose of ERISA 3(38), TFS Advisory services or other designated third-party manager serves as the investment manager, who exercises discretionary authority with regard to the model portfolios it develops and with regard to the mutual funds and other investment vehicles that it selects for investment under the Plan. Under ERISA 3(38), TFS Advisory Services or other designated third-party manager acts as the advisor with discretionary authority with regard to the investments managed for the plan, allowing the plan sponsor to transfer liability under his code section for selecting, monitoring, and replacing the investment options to TFS Advisory Services or other designated third-party investment manager. PENSION SERVICES CONSULTING TFS Advisory Services provides services to assist plan sponsors, plan trustees, investment committees and financial advisors to meet ERISA fiduciary responsibilities under 404(c). These consulting services range from the development of Investment Policy Statements to the delivery Participant Communication services. Investment Policy Statement Preparation (hereinafter referred to as ''IPS''): TFS Advisory Services will develop a Statement of Investment Policy for your retirement plan that provides the guidelines for selecting and evaluating investments offered in your plan. TFS Advisory Services will work with the organization to create an Investment Policy Statement consistent with ERISA guidelines. The Policy will document the plan's objectives and set into writing the plan's investment policies regarding investment selection, monitoring, benchmarking, and de-selection. Manager Selection: TFS Advisory Services and certain third-party designees provide investment manager research, benchmarking and selection process is a fully integrated process designed to select asset managers for each asset class and style to be represented within the plan. Our quantitative and qualitative screening ensures that each manager meets standards for style consistency, risk adjusted performance, consistency of performance and low expenses. Our team further assess the philosophy behind the numbers, the process by which it is implemented and most importantly - the people who manage the portfolios. Monitoring of Investment Performance: TFS Advisory Services or other designated third-party manager will establish and manage a process to select, de-select, and monitor investments offered to plan participants. TFS Advisory Services or its designated third-party managers will evaluate the plan's current offering by benchmarking the investment return, risk, and expenses to its peers and relative indices, by providing an assessment of asset class overlap or gaps, and by evaluating overall investment offering to the plan's current investment policy statement. Trustee & Investment Committee Meetings: TFS Advisory Services meets regularly with the Plan Trustees & Investment Committees to document the performance of the plan's investments and to make any recommendations that may be appropriate for changes. These meetings are documented and become part of the plan's due diligence file. Employee Communications: TFS Advisory Services will provide group meetings and individual participant meetings to help participants achieve better financial results. The schedule, timing and number of meetings shall be determined prior to contract acceptance. For pension, profit sharing and 401(k) plan clients with individual plan participants exercising control over assets in their own account (''self-directed plans''), we may also provide occasional educational support and investment workshops designed for the plan participants. The nature of the topics to be covered will be determined by us and the client under the guidelines established in ERISA Section 404(c). Employer Sponsored Retirement Plans (401(k) Plus) We also offer clients of TFS Advisory Services a proprietary 401(k) plan solution that allows us to manage the assets within a participant’s employer sponsored 401(k), pension or profit sharing plan. This program is co-branded and subadvised by RMS "Retirement Management Systems", an SEC Registered Investment Advisor, located at 441 Defense Highway, Suite C, Annapolis, MD 21404 (888) 870-7674. RMS currently has approximately $1 billion of defined contribution assets under management. Participation in this program does not allow breakpoints or linking with other TFS Advisory Services accounts. The program typically charges a flat annual fee, based on the range of assets in the participants plan. THIRD PARTY MANAGER PROGRAMS We also offer advisory management services to our clients through Third Party Manager Programs (hereinafter, "Programs"). Our firm may provide the client with an asset allocation strategy developed through personal discussions in which goals and objectives based on the client's particular circumstances are established. This asset allocation strategy is drafted into the client's Personal Investment Policy Statement ("PIPS"). Based on the client's individual circumstances and needs (as exhibited in the client's PIPS) we will then perform management searches of various unaffiliated registered investment advisors/ third party managers to identify which registered investment advisor's portfolio management style is appropriate for that client. Factors considered in making this determination include account size, risk tolerance, the opinion of each client and the investment philosophy of the selected registered investment advisor. Clients should refer to the selected registered investment advisor's Firm Brochure or other disclosure document for a full description of the services offered. We are available to meet with clients on a regular basis, or as determined by the client, to review the account. Once we determine the most suitable investment advisor(s) for the client, we may re-affirm the client's investment profile by completing the selected managers PIPS (if applicable). The third party adviser(s) then creates and manages the client's portfolio based on the client's individual needs as exhibited in the PIPS. We monitor the performance of the selected registered investment advisor(s). If we determine that a particular selected registered investment advisor(s) is not providing sufficient management services to the client, or is not managing the client's portfolio in a manner consistent with the client's PIPS, we may suggest that the client contract with a different registered investment advisor and/or program sponsor. Under this scenario, our firm assists the client in selecting a new registered investment advisor and/or program. However, any move to a new registered investment advisor and/or program is solely at the discretion of the client. Third Party Asset Management Programs ("TAMPS") Third Party Asset Management Programs ("TAMPS") The Registrant may recommend or select other investment advisors for its clients generally through Third Party Asset Management Programs ("TAMPs"). Envestnet Asset Management, Inc. ("Envestnet") makes available advisory services and programs of third party investment advisors. Through these TAMPs, the Registrant's representatives provide ongoing investment advice to clients that is tailored to the individual needs of the client. As part of these TAMP services, the representative typically obtains the necessary financial data from the client, assists the client in determining the suitability of the program, assists the client in setting an appropriate investment objective and risk tolerance and assists the client in opening an account with the TAMP. In addition, depending on the type of program, the representative may assist the client to select a model portfolio of securities designed by the TAMP or select a portfolio management firm to provide discretionary asset management services. It is the third party investment advisor (and not Registrant's representative) that has client authority to purchase and sell securities on a discretionary or non-discretionary basis pursuant to investment objective chosen by the client. This authorization will be set out in the TAMP client agreement. The Brochure for the particular TAMP will explain whether clients may impose restrictions on investing in certain securities or types of securities. In particular, the Registrant currently offers advisory services through TAMPs sponsored by,a variety of well diversified asset managers. Clients should refer to the Brochure, client agreement and other account paperwork for each TAMP for more detailed information about the services available under the program.
Insurance and Annuity Exchange (FIDx) The Insurance and Annuity Exchange, powered by Envestnet, provides end-to-end management of annuity solutions from pre-to post-issuance. Advisors can plan, research, generate proposals, open policies, manage in-force transactions, and create client reports within the Envestnet platform. Insurance and Annuity Exchange is a way to offer long term protection solutions to clients through a single, unified platform. FINANCIAL PLANNING AND CONSULTING TFS Advisory Services offers various types and levels of financial planning and consulting services. The level and type of services will vary among the Advisory Representatives and will depend on the needs of the client. Services may include, but not be limited to, the following examples of services. Retirement Planning General, Segmented and Comprehensive Financial Planning Educational Planning Cash Flow Analysis Estate Planning Budget Planning Tax Planning Insurance Needs Analysis Business Continuity, Succession and Exit Planning Asset Allocation Services Executive Planning Corporate Benefit Consulting Other planning and consulting services as requested by the client and agreed to by the Advisory Representative TFS Advisory Services will gather financial information and history from clients, which may include, among other things, retirement and financial goals, investment objectives, investment horizon, financial needs, cash flow analysis, cost of living needs, education needs, savings tendencies, and other applicable financial information required by TFS Advisory Services in order to provide the investment advisory services requested. As stated above, the level and type of services will depend on the needs of the client. Depending on the services requested, clients may receive a written analysis, summary or plan. One or more meetings may be necessary with the client and may involve other professionals, as invited and agreed to by the client, such as attorneys and/or certified public accountants. Planning and consultative services are based on the client's financial situation at the time and on financial information disclosed by the client. Clients are advised that plans may contain certain assumptions that may be made with respect to interest and inflation rates and use of past trends and performance of the market and economy. However, past performance is in no way an indication of future performance. TFS Advisory Services cannot offer any guarantees or promises that clients' financial goals and objectives will be met. Further, clients must continue to review any plan or analysis and update the plan based upon changes in the client's financial situation, goals, or objectives or changes in the economy. Should a clients' financial situation or investment goals or objectives change, clients must notify TFS Advisory Services promptly of the changes. Clients are advised that fees for planning and/or consultative services are strictly for the planning services. Therefore, clients may pay fees and/or commissions for additional services obtained, such as asset management or products purchased, such as securities or insurance. Financial plans will generally be prepared by the Investment Advisory Representatives (IAR), utilizing well known industry standard financial planning software programs including but not limited to EISI / NaviPlan, Money Tree, SunGuard and eMoney Advisor etc. Our investment recommendations in conjunction with financial plans are limited to the specific products or services offered by a broker-dealer or insurance company and will generally include advice regarding the following securities: Exchange-listed securities Securities traded over-the-counter Corporate debt securities (other than commercial paper) Certificates of deposit Municipal securities US Government securities Interests in partnerships investing in real estate Variable life insurance Variable annuities Fixed annuities Mutual fund shares Exchanged Traded Funds REITs- "Real Estate Investment Trust" BDCs - "Business Development Company" Other The financial plan is presented to the client as expeditiously as possible in relation to the contract date, provided that all information needed to prepare the financial plan has been promptly provided. CONSULTING SERVICES Clients can also receive investment advice on a more focused basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, and any other specific topic. In addition we provide specific consultation and administrative services regarding investment and financial concerns of the client. We also provide general non-securities advice on topics that may include tax and budgetary planning, divorce planning and business planning, including but not limited to mergers and acquisition business. We may advise on the facilitation of mergers and acquisitions, tender offers, financial restructurings, asset sales, divestitures and/or other corporate reorganizations or business combination transactions. AMOUNT OF MANAGED ASSETS