their own through Fidelity.com or inform TCM of any requested
changes.
Once the above account is established, the ROBS provider provides documentation that enables the
client to open a new company retirement plan. TCM then assists the client in facilitating the opening
and movement of funds to the clients new retirement plan account, as directed by the client. A phone
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conversation is conducted with the client to discuss timing of the transfer and the amounts that they
are requesting to be transferred to their new retirement plan account. To fund the client's business the
client or the retirement plan's trustee will often instruct TCM to prepare documents to transfer assets
into the business checking account. Any time funds are transferred internally between accounts held
at Fidelity, or to a bank account outside of Fidelity, a signed transfer form is required or signed
standing payment instructions need to be in place. The only individual who is able to request a
transfer from an account is the registered account owner. The only individual/individuals able to
transfer funds from the company retirement plan account are the trustees on the signed retirement
plan documents established by the ROBS provider.
Should a ROBS provider client decide that they do not wish to utilize the services of TCM from an
investment advisory perspective, then TCM will discuss with the client the various options that are
available. The options discussed are (i) leaving the account "as is," or (ii) terminating the relationship
with TCM. If the client chooses to leave their account exactly as is with the knowledge that they are
responsible for making any further investment changes to the account through Fidelity.com. TCM will
continue to provide support to these individuals by advising on the ROBS provider's process, assisting
with future account transfers, establishing any additional requested accounts for retirement plan
participants, and providing support to the ROBS provider staff with regards to any client account
information. If the client wishes to terminate their relationship with TCM, then TCM will remove the firm
from the client's accounts but only close the account if requested by the client.
There are many instances where clients do not sign our management agreement but still request that
we liquidate securities. In these situations TCM, acting in a non-discretionary manner, will require
client's instruction prior to placing any transactions. We encourage clients to
utilize
www.fidelity.com but we will often obtain verbal instructions to liquidate to raise cash to fund
business.
When an individual wishes to engage TCM for its investment management services, TCM conducts an
interview to discuss risk tolerance, investment time horizon, all other financial assets, current financial
situation and the overall financial outlook for the potential client. Additionally, TCM informs the
potential client of fees associated with engaging the services of TCM. An investment portfolio outline,
Discretionary Investment Management Agreement, Form ADV Part 2A and TCM Privacy Notice are
provided to the potential client in which their signature is requested in order to move forward with any
current or future investment advice.
Retirement Plan/Corporate Consulting Services
We offer retirement plan/corporate consulting services to corporations, employee benefit plans and
their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or
named fiduciary. In general, these services may include asset allocation analysis/advice, performance
reporting, performance attribution, education and enrollment services and compliance assessments.
These 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 provide additional types of corporate/retirement plan services 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 corporate/plan-level or participant-
level services) shall be detailed in a written agreement and be consistent with the parameters set forth
in plan documents.
Wrap Fee Program(s)
We do not sponsor or act as portfolio manager for any wrap fee programs.
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Types of Investments
We offer advice on equity securities, corporate debt securities (other than commercial paper),
certificates of deposit, municipal securities, options contracts on securities, money market funds and
ETFs.
Additionally, we may advise you on various types of investments based on your stated goals and
objectives. We may also provide advice on any type of investment held in your portfolio at the inception
of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the
investment advice we provide to you may be different or conflicting with the advice we give to other
clients regarding the same security or investment.
You may request that we refrain from investing in particular securities or certain types of securities.
You must provide these restrictions to our firm in writing.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
following acknowledgment to you. When we provide investment advice to you regarding your
retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I
of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable,
which are laws governing retirement accounts. The way we make money creates some conflicts with
your interests, so we operate under a special rule that requires us to act in your best interest and not
put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent
advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest.