This Disclosure document is being offered by WealthTrust Asset Management, LLC (the “Firm” or “WTAM”) in connection with the investment services we provide under our three business channels: Investment Advisory, Asset Management and RIA consulting and facilitation. It is intended to disclose information about the services we provide and the manner in which those services are made available. Our Firm was established in 2014 by John G. McHugh and became a registered investment adviser in 2015, with principal ownership by John G. McHugh. It is headquartered in Destin, Florida with branch offices in Plano, Texas and Mobile, Alabama. Investment Advisory services are performed under the name of TAMP Advisory Solutions (“TAMP”) which is a dba for the firm. While TAMP may be used interchangeably by our Investment Advisory division, for simplicity purposes in this brochure, we will use “TAMP” to refer to our Investment Advisory services. The Firm’s Asset Management division operates under the name WealthTrust Asset Management (“WealthTrust”) and offers discretionary model management under the WealthTrust DBS Portfolios. Our WealthTrust Portfolios are offered to investment advisory clients of our firm and unaffiliated investment advisors. As of December 31, 2020, our asset management business channel is our company's primary business in revenue and assets. The third division of the Firm markets its business under the name of 925 Advisory (“925”). 925 operates as an Advisory Services Platform to investment advisers for asset management and certain back-office services. As a registered investment adviser, we act as a fiduciary and it is our duty to always act in the client’s best interest. Asset Management Services Our Firm offers asset management services to unaffiliated registered investment advisers (hereafter referred to as “Independent RIA”) whereby our Firm manages some or all of these Independent RIA’s client (“Adviser Client”) assets according to the WealthTrust DBS Portfolio chosen by the Independent RIA. In these situations, the Adviser Client remains a client of the Independent RIA. The decision into which investment strategy(s) Adviser Client assets are invested is based on suitability information gathered and reviewed by the Independent RIA. Our Firm will manage these assets on a discretionary basis based on its investment strategies and not based on overall Adviser Client suitability. WealthTrust Asset Management Services are also offered to Trust Companies, Broker-Dealers, Qualified Retirement Plans and Family Offices. Management of these outside assets is facilitated through sub-advisory or tri-party agreements with the Independent RIA and our firm or by the Independent RIA’s access to the WealthTrust DBS portfolios through managed account platforms. Through an Independent RIA’s Sub-Advisory or Tri-Party Agreement with our firm, we will be given access to the Adviser Client accounts enrolled in our WealthTrust DBS management services. Our Firm will facilitate all the trading and rebalancing and may perform billing functions such as the deduction of management fees on behalf of the Independent RIA. WealthTrust will determine when existing positions will be liquidated to facilitate investing in our models. Our Firm will not tailor our models to accommodate any limitations or restrictions in the Adviser Client portfolios, however, accommodations may be approved for legacy positions on a case-by-case basis. WealthTrust will not have direct contact with individual Adviser Client, only communication with and direction by the Independent RIA. Through our agreement with an unaffiliated third-party Technology platform, Orion Advisor Services, our Firm may provide an online portal for both Adviser Clients and Independent RIAs. This portal will give access to reporting that details current positions and balances, asset allocation, transaction history and performance. Model Portfolio Subscription Services Our Firm offers WealthTrust DBS model portfolios on 3rd Party digital platforms to which independent financial institutions, including unaffiliated Registered Investment Advisors, banks, broker-dealers (“Financial Institutions”), may subscribe. These platforms allow Independent RIAs access to our Firm’s DBS portfolios as an investment option for their client accounts. Under this arrangement, our Firm will not be given access to Independent RIAs client accounts. Our Firm does not enter direct relationships with these clients nor the Independent RIAs. Instead, our Firm maintains, monitors, and supervises the DBS models on the subscribing firm’s platform, providing ongoing model updates as well as buy, sell, and rebalancing recommendations. On occasion, these models can hold slightly different funds than our direct discretionary asset management accounts due to custodial relationship constraints that are outside of our control. The Independent RIA Adviser(s) will be responsible for selecting the DBS model that is suitable for their client. Financial Institutions maintain their own custodial relationships and offer separate execution and clearing services. Subscribing firms or Independent RIAs are also responsible for providing all administrative and performance reporting services to their clients. Investment Services for Clients of Our Firm For clients of our Firm, we offer discretionary and non-discretionary investment management and investment monitoring services for an annual fee based on a percentage of the Client’s assets under management or a flat dollar amount. A flat dollar Minimum Annual Investment services fee may also apply. Discretionary asset management services include investment analysis, ongoing allocation of investments, and monitoring services for the portfolio. Non-Discretionary investment management will include investment analysis and recommendations to the Client, with all transactions being authorized by the Client. Investment Monitoring Services, without investment management, include a periodic review of the holdings within the account. Monitoring Services may be offered for non- discretionary accounts and there may be an Investment Services Fee assessed for these services. Zero Fee accounts, or accounts that are not being assessed a fee for services are managed by the Client without expectation of analysis, monitoring, or buy/sell recommendations by the Firm. All client accounts, regardless of services performed, will be included in Client account reviews with their Investment Advisor Representative. We help determine our Clients recommended portfolio composition based on their needs, accepted portfolio restrictions, if any, financial goals, and risk tolerance. We will work with our Clients to obtain necessary information regarding their financial condition, investment objectives, liquidity requirements, risk tolerance, time horizons, and any restrictions on investing. This enables us to determine the asset allocation we view as appropriate for our Client’s investment objectives and needs. In performing our services, we shall not be required to verify any information received from our Clients or from their other professionals. Upon request, we may recommend the services of other professionals, such as tax attorney’s or accountants, but Clients are under no obligation to engage the services of any such recommended professional. For discretionary account management, once we have determined the types of investments to be included in our Clients portfolio, and allocated them, we will provide ongoing portfolio review and management services. This approach requires us to review our Clients portfolio at least quarterly. Under discretionary management, we are authorized to trade and rebalance the investment account as we deem appropriate, without consultation with the Client. This includes discretion of all investment decisions and all trades entered. For non-discretionary accounts, client’s retain control over investment decisions. While we may render investment advice and recommendations, all investment decisions will be made by the Client. No purchase, sale, or other transaction(s) will be made with respect to any security or other assets in the Account without the Client’s authorization. It is at the discretion of the client as to whether to follow, or not to follow the investment advice provided by the Firm. Clients will have the ability to leave standing instructions with us to refrain from investing in particular industries or invest in limited amounts of securities, including socially conscious investment preferences or restrictions. We will try, as much as possible, to accommodate these requests, but such requests are not guaranteed to be honored. It should be understood that investment in certain securities such as mutual funds or Exchange Traded Funds (“ETFs”) may make it impossible for us to ensure that a client’s portfolio will not invest in a particular industry or security. Account holders have a direct and beneficial interest in their securities, rather than an undivided interest in a pool of securities. Clients of our Firm are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks exist that may adversely affect an account’s performance and result in capital losses. We do not guarantee the results of asset management performed or consulting advice we give, including the performance of our WealthTrust Asset Management DBS portfolios. Thus, significant losses can occur by using our services. We may offer an initial complimentary meeting with our clients; however, investment advisory services are initiated only after our Clients and the Firm execute a Client Engagement Agreement. Clients may also engage WTAM to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts. In these situations, WTAM will direct or make recommendations for the allocation of

client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or custodian and clients retain responsibility for effecting trades in these accounts. For these services WTAM will charge no more than 1% of AUM and require a signed client agreement. Retirement Plan Investment Advisory Services Retirement Plan Advisory Services consists of assisting employer plan sponsors establish, monitor and review their company's retirement plan. As the needs of the plan sponsor dictate, areas of advising could include investment selection and monitoring, plan structure, and participant education. We will help evaluate our Clients plan’s needs and objectives through an initial meeting to collect data, review plan information, and assist our Clients in developing or updating the plan’s provisions. Ongoing services to our Clients may include recommendations regarding the selection and review of unaffiliated mutual funds that, in our judgment, are suitable for plan assets for our Clients to be invested. We periodically review the investment options our Clients select and make recommendations to keep or replace plan investment options as appropriate. We perform a comprehensive review of potential service providers or vendors and will assist our Clients with converting from their incumbent service provider to a new service provider they select. Our Clients are under no obligation to follow the recommendations we make. Services available under a Client Engagement Agreement permit us to provide financial education to our Clients’ plan participants. The scope of education provided to participants at our Clients request will not constitute “investment advice” within the meaning of ERISA and participant education will relate to general principles for investing and information about the investment options currently in the plan. We may also participate in initial enrollment meetings and periodic workshops and enrollment meetings for new participants as we agree upon. All Retirement Plan Advisory Services shall be in compliance with any applicable Federal and State law(s) regulating the services provided by our Agreement. This section applies to an Account that is a pension or other employee benefit plan (a “Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If our Clients Account is part of a Plan and we accept appointments to provide our services to our Clients Account, we acknowledge that we are a fiduciary within the meaning of Section 3(21) of ERISA (but only with respect to the provision of services described in section 1 of this agreement). Our Clients represent that (i) Our appointment and services are consistent with the Plan documents, (ii) Our Clients have furnished us true and complete copies of all documents establishing and governing the Plan and evidencing their authority to retain our firm. Our Clients further represent that they will promptly furnish us with any amendments to the Plan, and agree that, if any amendment affects our rights or obligations, such amendment will be binding on us only with our prior written consent. If our Clients Account contains only a part of the assets of the Plan, they understand that we will have no responsibilities for the diversification of the Plan’s investments, and we have no duty, responsibility or liability for the assets that are not in the account. If ERISA or other applicable law requires bonding with respect to the assets in our Client’s account, they will obtain and maintain at their expense bonding that satisfies this requirement and covers the Firm and any of our affiliates. Financial Planning Services Financial advisory services provided by us to our Clients may include the analysis of their situation and assistance in identifying and implementing appropriate financial planning and investment management techniques to help the client meet their specific financial objectives. Such service may include a written financial analysis and specific or general investment and/or planning recommendations. Financial Plans offered by the Firm and its IARs have a focus on long term investment planning. In preparing our Clients financial plan, we may address any or all of the six areas of financial planning established by the National Endowment for Financial Education and endorsed by the Certified Financial Planner Board of Standards, depending on our Clients specific needs. These include financial position, protection planning, investment planning, income tax planning, retirement planning, and estate planning. Our specific services in preparing our Client’s plan may include:
• Review and clarification of our Client’s financial goals.
• Assessment of our Clients overall financial position including cash flow, balance sheet, investment strategy, risk management and estate planning.
• Create of a unique plan for each goal our Clients have including personal and business real estate, education, retirement or financial independence, charitable giving, estate planning, business succession and other personal goals.
• Develop of a goal-oriented investment plan around tax suggestions, asset allocation, expenses, risk and liquidity factors for each goal. This includes IRA and qualified plans, taxable and trust accounts that require special attention.
• Design a complete risk management plan including risk tolerance, risk avoidance, mitigation and transfer, including liquidity as well as various insurance and possible company benefits.
• Craft and implement, in conjunction with our Clients estate and/or corporate attorneys as tax advisor, an estate plan to provide for our Clients and/or our Clients’ heirs in the event of an incapacity or death. We also provide clients investment advice on a more limited basis on one or more isolated areas of concern such as estate planning, retirement planning, or any other specific topic. Additionally, we may provide advice on non-securities matters in connection with the rendering of estate planning, insurance, and/or annuity advice. Our Investment Advisor Representatives with Branded Practices Your IAR may market their practice under one of our firm’s dba names, TAMP Advisory Solutions. In addition, some of our firm’s IARs have branded their practices with their own independent legal business entity name. The Client should understand that the independent businesses are legal entities of the IAR and not of our firm. However, regardless of the name under which our IAR markets their practice, all of our IARs are under the supervision of our firm and their advisory services are provided through our firm. A complete listing of these entities is listed on our ADV Part 1. Pricing Structure for Investment Services (Wrap and Non-Wrap) Wrap Accounts – The investment services fee stated in the Client Engagement Agreement includes the investment services and all transaction costs. Non-Wrap Accounts – The investment services fee stated in the Client Engagement Agreement covers the investment services only. Transaction costs will be billed by the custodian in addition to the investment services fee. Prior to 10/1/2021, services to our clients were offered under a “wrap” or “non-wrap” pricing structure. However, in an effort for transparency of charges incurred in a Client’s account, effective 10/1/21 our firm began phasing out our wrap fee program. And, as a result, all new Client accounts are priced on a “Non-Wrap” basis. Non-Wrap pricing allows the fee stated in the Client Engagement agreement to solely encompass Investment Advisory and Asset Management services provided by our firm. Any transaction costs are charged directly to the Client account by the Custodian. Clients with legacy accounts that are priced under our wrap fee program are encouraged to change to non-wrap pricing. Because this change in pricing may result in additional costs to the Client, these costs should be reviewed by the Client and their Investment Advisor Representative. Wrap and Non-Wrap designations refer to the pricing structure of a Client account and have no bearing on the investment services provided to those accounts by the Firm. Our Firm does not manage wrap fee accounts in a different fashion than non-wrap fee accounts. Details of our Firm’s legacy Wrap Fee Program are contained in the firm’s ADV 2A Wrap Program Brochure. Written Acknowledgement of Fiduciary Status 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. Assets Regulatory Assets Under Management (RAUM) - As of December 31, 2023, we have $ 158,339,606 regulatory assets under discretionary management and $ 21,672,780 regulatory assets under non-discretionary management. Assets Under Advisement (AUA) - Our Assets Under Advisement as of December 31, 2023 total $ 97,654,016.