1
Asset Management Consulting
SM
Truist Advisory Services, Inc. Wrap Fee Programs
AMC Advisor Managed Programs
• AMC Advise
• AMC Allocation Plus
• AMC Annuity
Truist Advisory Services, Inc. and Third-Party Managed Programs
• AMC Fund Select Tactical
SM
• AMC Fund Select Tactical Focus
SM
• AMC Pinnacle
SM
• AMC Pinnacle – Sleeve Select
• AMC Premier
SM
o Envestnet Sentry
• AMC Truist Invest
Truist Advisory Services, Inc. Model Manager, Research and Other Services
Truist Advisory Services, Inc.
303 Peachtree Center Avenue, Suite 140, Atlanta, GA 30303
SEC File Number 801-107729
August 22, 2024
This wrap fee brochure provides information about the qualifications and business practices of Truist Advisory
Services, Inc. If Client has any questions about the contents of this brochure, please contact Truist Advisory
Services, Inc. at (855) 815-9688 Option #2, then #4. The information in this brochure has not been approved or
verified by the United State Securities and Exchange Commission or any state securities authority.
Registration as an investment adviser does not imply a certain level of skill or training.
Additional information about Truist Advisory Services, Inc. is also available on the SEC’s website at
www.adviserinfo.sec.gov.
Investment and Insurance Products:
•Are not FDIC or any other Government Agency Insured •Are not Bank Guaranteed •May Lose Value
https://www.truist.com/wealth/tas-disclosure
MATERIAL CHANGES
The last update was July 2, 2024.
The following material changes were added to the Disciplinary Information section:
On August 14, 2024, the SEC announced the settled administrative order entered into by Truist Securities, Inc.,
Truist Investment Services, Inc. and Truist Advisory Services, Inc. (collectively, “Truist”) following the firm's Offer
of Settlement. The order was entered following Truist’s identification and self-disclosure of the unauthorized use
of off-channel communications to conduct SEC-regulated business. The order stated that certain employees of
Truist used off-channel communications against Truist policies. In addition, the order noted that Truist did not
maintain the off-channel communications or reasonably supervise employees in relation to off-channel
communications. Truist admitted the SEC's findings of fact, acknowledged that its conduct violated the federal
securities laws, agreed to retain a compliance consultant to review relevant policies and procedures, and agreed
to the making, keeping and preserving of certain required books and records. The order censured the firm,
required that the firm cease and desist from violating the federal securities laws cited in the order, and imposed a
civil money penalty in the amount of $5,500,000.
On August 14, 2024, Truist Bank consented to entry of a CFTC Order instituting administrative and cease-and-
desist proceedings and imposing remedial actions, following its identification and self-disclosure of substantially
similar conduct, Under the CFTC Order, Truist Bank paid a civil penalty of $3,000,000 on August 21, 2024, and
agreed to undertake a similar compliance review.
Table of Contents
Cover Page 1
Material Changes 2
Table of Contents 3
Services, Fees and Compensation 7
Account Requirements and Types of Clients 22
Portfolio Manager and Model Manager Selection and Evaluation 23
Conflicts of Interest 24
Advisory Services 33
Methods of Analysis, Investment Strategies and Risk of Loss 46
Voting Client Securities 54
Client Information Provided to Portfolio Managers 55
Client Contact with Portfolio Managers 56
Additional Information 56
Disciplinary Information 56
Other Financial Industry Activities and Affiliations 58
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 59
Review of Accounts 60
Payment for Client Referrals 61
Index 63
Truist Advisory Services, Inc. Wrap Fee Programs Brochure
Investing in securities and other investment products involves risk of loss that Clients should be prepared to bear.
The investment performance and success of any particular investment cannot be predicted or guaranteed, and
the value of a Client’s investments will fluctuate due to market conditions and other factors. Investments are
subject to various risks, including, but not limited to, market, liquidity, currency, economic and political risks, and
will not necessarily be profitable. Past performance of investments is not indicative of future performance.
SERVICES, FEES AND COMPENSATION
Truist Advisory Services, Inc. (“TAS” or the “Firm”) is an investment adviser registered with the U.S. Exchange
Commission (“SEC”) and a separate, wholly owned, non-bank subsidiary of Truist Financial Corporation (“TFC”)
and an affiliate of Truist Bank (“TB”). TAS became an investment adviser under the Investment Advisers Act of
1940 (“the Advisers Act” or “the Act”), as amended, in April 2016. TAS is a fiduciary under the Investment Advisers
Act of 1940 and is subject to the fiduciary standard imposed by the Act, SEC Regulations and other applicable
laws and regulations.
This Truist Advisory Services, Inc. Wrap Fee Programs Brochure (“brochure”) covers information about certain
Asset Management Consulting (“AMC”) investment advisory Programs described in this brochure (“AMC
Programs”, each an “AMC Program” or “Program”) wrap fee programs offered by TAS. Wrap fee programs are
those investment advisory programs in which the Client is charged one fee (the “Program Fee”), based on the
assets in a Client’s investment advisory account subject to an investment adviser’s management services. The
total Program Fee includes (i) the investment advisor’s compensation for management and the execution and
clearing costs associated with the trades the investment adviser recommends or submits on behalf of the Client
related to the assets being managed by the investment adviser, and (ii) any additional fees paid to unaffiliated
investment managers (each a “Third Party Managers”) and unaffiliated investment model providers (each a “Third
Party Model Providers” or “Third Party Models”) and the custody of those assets.
TAS makes a wide variety of securities and other investment products available to AMC Program
accounts. TAS, however, does not offer all available investment types and investment products to AMC
Program accounts. Instead, each AMC Program offers AMC Program accounts only securities and other
investment products reviewed and selected by TAS, a TAS Advisor or another model provider or
investment manager and determined to be eligible investments for each Program. The limitation of
investment products available to AMC Program accounts creates a conflict of interest for TAS in
connection with the management of AMC Program Accounts. See Conflicts of Interest - Other Investment
Products Available Section below.
TIS Brokerage Account Enrollment Required
Unless otherwise expressly permitted by the terms of the applicable AMC Program, investment in any of the AMC
Programs described in this brochure requires that Client separately maintain or open an underlying brokerage
account with TAS’s affiliated broker-dealer and insurance agency, Truist Investment Services, Inc. (“TIS”).
Client’s TIS brokerage account is governed by a TIS Brokerage Account Customer Agreement (“Brokerage
Agreement”). However, under certain circumstances, assets can be held at another financial institution, such as
Truist Bank. TIS is a member of the Financial Industry Regulatory Authority (“FINRA”) and Securities Investor
Protection Corporation (“SIPC”). TIS is an introducing broker-dealer which in the ordinary course of business
generally clears its equity and option trade orders related to the AMC Program accounts described in this brochure
through National Financial Services LLC (”NFS”). However, in an effort to obtain best execution for Clients, in
certain cases TIS may route certain larger equity and option orders and orders with special handling instructions
to other market centers and broker-dealers. TIS does not receive any compensation related to the alternative
routing of such orders. TIS acts as Non-Bank Custodian for most IRA accounts which are advised and/or managed
by TAS and through NFS, acting as TIS’ agent, has custody of securities held by AMC Program accounts. Fidelity
Management Trust Company, an affiliate of NFS, currently serves as Non-Bank Custodian for all AMC Program
IRA accounts not presently serviced by TIS in this capacity (“FMTC Custodian Accounts”).
For the AMC Annuity Program TAS has entered into a tri-party agreement with TIS and the selected annuity
carrier(s). The annuity carrier provides clearing, custody and execution services for the Client’s annuity. The
requirement to open a brokerage account with an affiliated broker is made by TAS for purposes of efficiently
administering its Programs and this requirement also provides additional benefits to TAS and its affiliates which
creates additional conflicts of interest with respect to TAS’s management of AMC Program Accounts. See
Conflicts of Interest –Use of Affiliated Broker Dealer Section below.
Inconsistent Brokerage Account Risk Tolerance and Investment Objectives
Client risk tolerance and investment objectives of a Client’s underlying TIS brokerage account do not in all cases
specifically match the investment advisory account risk profile of the Client’s AMC Program account within the
Envestnet system which TAS utilizes to manage how account investment risk classifications are captured and
monitored. In the case of any discrepancy in risk ratings, each Client AMC Program account is managed by TAS
in accordance with the risk rating applicable to the Client’s AMC Program investment advisory relationship and
not in accordance with any risk rating applicable to Client’s pre-existing brokerage relationship.
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The following chart lists the descriptions of each risk rating Conservative, Income with Growth, Balanced, Growth
with Income and Growth in the TAS Envestnet platform (used by all Programs other than the AMC Truist Invest
Program).
ENVESTNET PLATFORM*
Risk Rating
with Asset Allocation
Ranges
Risk Descriptions with Equity (EQ) / Fixed Income (FI) Allocation Ranges
Conservative
This investment objective is generally focused on the production of current income
with some protection of purchasing power expected over the long term. Portfolios
will typically be significantly invested in high quality income investments with some
equity and non- traditional investment exposure in order to protect capital over the
longer term.
AMC Pinnacle
EQ: 0% - 40%
FI: 60% - 100%
AMC Advise and
AMC Allocation Plus
Maximum Equity Exposure
40%
Income with Growth
AMC Pinnacle
Eq: 15% - 55%
FI 45% - 85%
AMC Advise and AMC
Allocation Plus
Maximum Equity Exposure
55%
This investment objective is generally focused on providing current income, while
also providing an opportunity for modest capital appreciation over the long term.
Portfolios will typically have a greater exposure to fixed income securities with
some equity and non- traditional investment exposure in order provide growth and
diversification over time.
Balanced
This investment objective is focused on balancing the goals of both the growth of
principal and purchasing power protection with current income production.
Portfolios are typically allocated across major asset categories.
AMC Pinnacle
EQ: 30% - 70%
FI: 25% - 65%
AMC Advise and AMC
Allocation Plus
Maximum Equity Exposure
70%
Growth with Income
This investment objective is focused on capital appreciation while providing a low
to moderate level of income. Portfolios are typically allocated more heavily to
equity investments with some fixed income and non- traditional investment
exposure in order to protect capital over the longer term.
AMC Pinnacle
EQ: 50% - 90%
FI: 10% - 50%
AMC Advise and AMC
Allocation Plus
Maximum Equity Exposure
90%
Growth
This investment objective is focused on capital appreciation. Portfolios will typically
be concentrated in equity investments with portfolio enhancing fixed income and
non-traditional investments.
AMC Pinnacle
EQ: 60% - 100%
FI: 0% - 30%
AMC Advise and AMC
Allocation Plus
Maximum Equity Exposure
100%
*This chart does not reflect the AMC Truist Invest Program Risk Rating Allocations.
SERVICES AND PROGRAMS DESCRIBED IN THIS BROCHURE
TAS offers wrap portfolios managed by TAS advisors (AMC Advisor Managed Programs) or TAS and/or affiliated
or non- affiliated third-party managers (TAS and Third-Party Manager Programs).
AMC Advisor Managed Programs include the following Programs described below in general and in more detail in
Section ADVISORY SERVICES below:
• AMC Advise
• AMC Allocation Plus
• AMC Annuity
AMC Advise
The AMC Advise Program is a discretionary, investment management Program offering individualized investment
management by approved TAS Advisors for an asset-based fee. Clients do not direct transactions for their
accounts enrolled in this Program. Instead, the Client authorizes an approved TAS Advisor to manage the Client’s
designated assets on a discretionary basis by purchasing and/or selling individual stocks, bonds, mutual funds,
closed-end funds, exchange-traded funds, certificates of deposit, money market instruments, depository receipts
or other similar instruments relating to any of these securities within guidelines set by the TIS/TAS Policy
Committee for portfolio construction and limitation of risk. Limited types of options transactions are permitted in
the Program.
AMC Allocation Plus
The AMC Allocation Plus is a non-discretionary investment advisory Program offering individualized investment
recommendations by TAS Advisors for an asset-based fee. Investment decisions for accounts enrolled in this
Program are those of the Client and not their TAS Advisor or TAS. The TAS Advisor will be primarily responsible
for making investment management recommendations, in accordance with Client’s investment objectives as
stated in the Client’s Client profile, which the Client can elect to use to invest and reinvest the assets in securities
which includes various types of investment vehicles, such as common and preferred stocks, shares of mutual
funds, closed-end funds, exchange-traded funds, alternative investments, public and private, including hedge
funds and fund of funds, corporate, municipal or governmental bonds, notes, or bills and private equity. Margin and
limited types of options transactions are permitted in the Program.
AMC Annuity
The AMC Annuity Program is a non-discretionary investment advisory Program account offering individualized
investment recommendations by TAS Advisors. Investment decisions for accounts enrolled in this Program are
those of the Client and not their TAS Advisor or TAS. The TAS Advisor will be primarily responsible for making
recommendations in accordance with Client’s investment objectives as stated in the Client’s Client profile, which
the Client can elect to use in connection with selecting an annuity product to purchase and investing in investment
options made available by the annuity provider.
Variable annuities (“VAs” each a “VA”) are deferred annuities offered by insurance companies that provides
investment returns based on the performance of market-based subaccounts or indexed-linked segments. VAs are
flexible contracts that can provide Clients with variety of solutions, including the option to provide for guaranteed
living and death benefits. VAs are market based and can lose value based on market performance. Before
purchasing a VA, Clients are encouraged to review each VA’s prospectus in detail for a complete description of all the
features, risks, and benefits associated with the product. Annuities are not FDIC insured and all guarantees are
subject to the claims paying ability of the issuing insurance company. Annuity contracts are subject to federal
income tax penalties for withdrawals prior to age 59 ½. Additionally, VAs held in a tax-qualified account (including
IRAs) receive the same tax benefits as those held outside of a tax-qualified account. No additional tax benefits
result from purchasing or holding an annuity in a tax qualified account.
Fixed Index Annuities (“FIAs” each a “FIA”) are deferred annuities offered by insurance companies that provide
investment returns based on the performance of an underlying index. FIAs are flexible contracts that can provide
Clients with variety of solutions, including the option to provide for guaranteed living and death benefits. FIAs are
market based but offer a floor to protect a Client against market-related losses if contracts are held for the entirety
of the surrender period. If contracts are liquidated prior to the end of a surrender period or if partial withdrawals
are taken prior to the end of a surrender period, Clients can experience a loss. Before purchasing a FIA, Clients
are encouraged to review each FIA’s offering document in detail for a complete description of all the features, risks,
and benefits associated with the product. Annuities are not FDIC insured and all guarantees are subject to the
claims paying ability of the issuing insurance company. Annuity contracts are subject to federal income tax
penalties for withdrawals prior to age 59 ½. Additionally, FIs held in a tax-qualified account (including IRAs) receive
the same tax benefits as those held outside of a tax-qualified account. No additional tax benefits result from
purchasing or holding an annuity in a tax qualified account.
TAS and Third-Party Managed Programs include the following Programs described below in general and in more
detail in Section ADVISORY SERVICES below:
• AMC Fund Select Tactical and AMC Fund Select Tactical Focus
• AMC Pinnacle
• AMC Pinnacle – Sleeve Select
• AMC Premier
o Envestnet Sentry
• AMC Truist Invest
AMC Fund Select Tactical
The AMC Fund Select Tactical Program is a discretionary investment management Program offering Client
accounts enrolled in the Program an array of Exchange Traded Fund (“ETF”) portfolios, mutual fund portfolios
and Third Party Models based on risk-based modeling using asset allocation for an asset-based fee. Clients do
not direct investment transactions for their accounts enrolled in this Program. Instead, Client accounts will be
invested in accordance with Client’s investment objectives as stated in the Client’s Client profile on a discretionary
basis utilizing ETF asset allocation model portfolios provided by TAS’ IAG or Third Party Model Providers which
reflect differing risk profiles. Third-Party Models may also include mutual funds, as well as other securities. TAS
is granted discretionary investment authority over account assets.
AMC Fund Select Tactical Focus
The AMC Fund Select Tactical Focus Program is a discretionary investment management Program offering Client
accounts enrolled in the Program an array of Exchange Traded Fund (“ETF”) portfolios or Third Party Model
Provider model portfolios and are based on risk-based modeling using asset allocation for an asset-based fee.
Clients do not direct investment transactions for their accounts enrolled in this Program. Instead, Client accounts
will be invested in accordance with Client’s investment objectives as stated in the Client’s Client profile on a
discretionary basis utilizing ETF asset allocation model portfolios provided by TAS’ IAG or Third Party Model
Providers which reflect differing risk profiles. Third-Party Models may also include mutual funds, as well as other
securities. TAS is granted discretionary investment authority over account assets. TAS is granted discretionary
investment authority over account assets.
The principal difference between the AMC Fund Select Tactical Program and the AMC Fund Select Tactical Focus
Program are that the Fund Select Tactical Focus Program 1) offers fewer available models/investment options
and 2) has a lower minimum required funding amount than the AMC Fund Select Tactical Program.
AMC Pinnacle
The AMC Pinnacle Program is a unified managed account program, (“UMA”) that allows Clients to open and/or
maintain multiple advisory strategies in one underlying TIS brokerage account resulting in one investment account
for reporting the Client’s assets, performance and management fee processing. Clients elect the investment
transactions for their accounts enrolled in the Advisor Managed Non-Discretionary Sleeve Program but do not
direct investment transactions for their accounts enrolled in the Advisor Managed Discretionary or SMA Sleeves
of this Program. Client accounts enrolled in the Program can select multiple advisory strategies (each a “Sleeve”)
from the following: Strategist Sleeve, Advisor Managed Sleeves, Manager Model Sleeve and Fixed Income
Manager Sleeve (each described more fully below). Clients can move assets from one Sleeve to another within
the Program without having to complete additional account documentation.
For certain previously established AMC Pinnacle accounts, Advisors may, in the exercise of their discretion (1)
elect to allocation contributions or make withdrawals from a specific Sleeve and/or (ii) elect to allocate
contributions or make withdrawals from the entire portfolio based on the overall weights to each Sleeve.
AMC Pinnacle – Sleeve Select
All accounts in the AMC Pinnacle – Sleeve Select Program grant Advisors discretion to (i) elect to allocate
contributions or make withdrawals from a specific Sleeve and/or (ii) allocate contributions or make withdrawals
from the entire portfolio based on the overall weights to each Sleeve.
AMC Premier
The AMC Premier Program is a discretionary investment management Program offering Client accounts enrolled
in the Program the portfolio management services of a select, pre-screened group of investment managers, which
are made available to Client Program accounts through TAS which contracts both directly with some investment
manager(s) to provide separate account management services to Client Program accounts and with Envestnet
who contracts directly with additional investment managers. In either instance, Clients do not direct investment
transactions for their accounts enrolled in this Program. Instead, TAS manages each Client’s designated assets
in accordance with Client’s investment objectives as stated in the Client’s Client profile on a discretionary basis
utilizing affiliated and unaffiliated investment managers selected by each Client. Program Clients grant
discretionary portfolio management authority to the investment manager(s) they select. Each Third-Party
Investment Manager(s) offered to Clients is evaluated by either TAS’ due diligence and research process in an
identical manner or Envestnet.
One or more Third-Party Investment Managers (“Options Managers”) offer concentrated stock, index call and put
writing (income), Put Buying (protection) and/or Enhanced Income Yield option overlay management services to
Program Clients. Options Managers only trade in option contacts and do not manage the underlying stock or
other securities contained in the Client’s Program account. Clients electing Options Managers services will need
to contact their TAS Advisor when transaction in underlying securities are needed for cash flow to support option
contract margin requirements, settle options transactions or for other investment reasons. Enrollment in Options
Managers services will require Clients to complete additional documentation and acknowledge their
understanding of the risks associated with option investing. Clients must also agree to the terms of an options
account agreement and will receive separate options disclosure material. Both TIS and Clearing Broker must
approve the Client’s account for option trading prior to the implementation of Options Managers services. If margin
loan capabilities are required in connection with the establishment of Client’s options account Client must enter
into a margin agreement with the Clearing Broker. Clients should carefully review the margin disclosure in the
Program Fees Section of the General Terms and Conditions before electing margin capabilities.
Upon termination of an advisory agreement with an Options Manager or a change to a different Options Manager
that does not utilize overlay portfolios, the applicable option and/or margin agreements may be removed from the
Program account. To employ an option strategy at a later date, either in the TIS brokerage account or a TAS
advisory account, new agreements would need to be submitted for review and approval.
Program Fees applicable to Client’s option positions will be charged based on collateral value rather than the
market value of the options held in Client’s account.
AMC Fund Select Tactical and AMC Premier and Sentry– Fidelity Investments® Charitable Gift Fund
TAS has entered into an agreement with Fidelity Investments® Charitable Gift Fund (“Fidelity Charitable®”) to
offer charitable “Giving Accounts” established with Fidelity Charitable to its Clients. In accordance with the terms
of the agreement with Fidelity Charitable, the TAS AMC Fund Select Tactical and AMC Premier Programs are
presently the only AMC Programs eligible for investment of Giving Accounts.
Giving Accounts established with Fidelity Charitable are irrevocable charitable gifts to the Fidelity Investments
Charitable Gift Fund. The assets of each Giving Account are held and remain the sole property of the Trustees of
Fidelity Investments Charitable Gift Fund, who have exclusive ownership and legal control over the balances, as
well as complete and sole discretion over investment decisions regarding each Giving Account. However, Fidelity
Charitable allows the donor of a Giving Account or their designee (“Account Holder”) to have certain advisory
privileges over the Giving Account with respect to distributions and investments.
Envestnet Sentry
TAS has contracted directly with Third Party Managers and with Envestnet, which contracts directly with additional
Third Party Managers, to offer Envestnet’s or TAS’ separate managed account program, Envestnet Sentry.
In connection with the AMC Premier, Envestnet Sentry, AMC Pinnacle and AMC Pinnacle – Sleeve Select
Programs. Envestnet’s services include:
• Providing access to SMA investment managers (“Envestnet Managers”). These managers have
entered into sub- management agreements with Envestnet to provide discretionary account
management services;
• Providing administrative and /or trading services as directed by an Envestnet Manager;
• Rebalancing services to maintain an account’s asset allocation; and
• Acting on any reasonable restrictions that a Client elects to impose on the management of an account
including designation of particular securities or types of securities that Client does not want purchased.
TAS will recommend an appropriate asset allocation among the investment managers in the Envestnet Sentry
Program and recommend investment manager(s) for Client’s Program accounts. In recommending investment
managers for the Program accounts, TAS will consider factors it deems relevant, including but not limited to, the
investment goals and objectives of Client, and any reasonable restrictions imposed by Client on management of
the Program accounts, including the designation of particular securities or types of securities that should not be
purchased for the Program accounts, or that should be sold if held in Program accounts.
AMC Truist Invest
The AMC Truist Invest Program is an automated electronic discretionary investment advisory program offering
individualized investment recommendations by TAS Advisors for an asset-based fee. Clients do not direct
investment transactions for their accounts enrolled in this Program. Instead, the AMC Truist Invest Program is
offered by a Truist Advisor and utilizes a computer algorithm (“Algorithm”) to generate projections and make
discretionary investment decisions separately for each Program account. The TAS Advisor is primarily
responsible for making investment management recommendations, in accordance with Client’s investment
objectives related to one of the following goals: Retirement, Major Purchase or General Investing and the type of
portfolio which is limited in number and based on the Client’s risk tolerance. Each Program account may only
have a single selected goal.
In order to participate in the AMC Truist, Invest Program, Clients are required to agree that all records and
disclosures for the Program will be delivered, and all account agreements will be signed, electronically.
Financial Planning Services
Clients invested in AMC program accounts may also request that TAS and their TAS Advisor provide them with
additional complimentary Financial Planning Services (“Financial Planning Services”) utilizing Firm approved
computerized financial planning software. Clients with advanced financial planning needs may also separately
contract with the Firm for additional services. Financial Planning Services are also in certain circumstances
provided by the Firm’s affiliate, Truist Bank.
In preparing a financial plan or report for Clients, information deemed relevant to the particular service is gathered
through personal interviews and through documents and/or other information supplied by the Client. Each service
includes an analysis of the Clients’ information which may, but is not necessarily required, to include such things
as their current assets and investments, liabilities,
The results and other information generated by the Firm’s financial planning software regarding the likelihood of
various investment outcomes (“Reports”) are educational and hypothetical in nature, are not reflective of any
specific product, do not include any fees or expenses that may be incurred by investing in specific products, do
not reflect actual investment results, are not specific investment advice or recommendations and are not
guarantees of future results. The Reports are dependent on information provided by each Client with respect to
the Client’s income, current assets and investment, retirement and or spending goals, as applicable.
The actual returns of a specific investment product may be more or less than the returns used in the Reports
forecasts, rates of return, risk, inflation, and other assumptions may be used as the basis for illustrations contained
int he Reports and should not be considered a guarantee of future performance or a guarantee of achieving overall
financial objectives. Past performance is not a guarantee or a predictor of future results of any specified
investment index or any particular investment. Report results may vary with each use and over time.
Truist Wealth
Information presented in the Reports is for educational and illustrative purposes only and is not intended to
constitute or offer legal, accounting, tax, or other professional advice. For advice on these aspects of an overall
financial plan Clients must consult a qualified professional. TAS and Truist Bank, and their respective employees)
do not offer tax, accounting or legal advice.
In connection with Financial Planning Services, strategies may be proposed that include acquisition of securities,
insurance and other financial products. Should a Client accept the Firm’s Financial Planning Services and decide
to implement any financial planning option contained in any Report through TAS and/or its affiliates Client
represents and warrants to TAS and Truist Bank that Client is aware that:
• Clients have sole discretion whether to accept or reject wholly or partially, any such proposals and are
free to select any bank, trust company, investment advisory firm, broker/dealer or insurance agency for
implementation of advice or recommendations provided in the Report or by TAS or Truist Bank.
• The TAS Advisor (or Truist Bank representative) providing Financial Planning Services who prepared your
financial plan will receive compensation for AMC Program Accounts and other investment products
offered to you by TAS and its affiliates you based on the Reports.
• TAS’s affiliate, Truist Investment Services, Inc. (“TIS”), is a registered broker-dealer and an insurance
agency and that the TAS Advisor (and, except in certain cases, Truist Bank representative) providing a
Financial Planning Services who prepared your financial plan is also registered as a securities
representative for TIS and may also be licensed insurance agents of TIS and that is such capacities the
TAS Advisor s (or Truist Bank representative) will receive commissions and other remuneration resulting
from Client transactions effected through TIS (other than in the case of AMC program accounts).
• A conflict of interest exists when TAS or Truist Bank personnel receive a commission or other
remuneration for providing investment advisory or other investment management services and/or
effecting securities and/or insurance transactions relating to advice given and that any investments,
insurance and investment advisory and investment management services recommended by TAS or Truist
Bank may be available from other firms at higher or lower charges. See Conflicts of Interest - Section
below.
Financial Planning Services are offered as b TAS and Truist Bank upon Client request. After a Report is delivered
to a Client all Financial Planning Services TAS (or Truist Bank) will no longer maintain a financial planning
relationship with Client and any investment advisory relationship created thereby will cease and any Client’s
financial plan or Report will not be monitored or updated except upon Client’s further specific request and TAS or
Truist’s Bank subsequent agreement to again provide Client with Financial Planning Services.
Should Client elect to engage TAS or any of its affiliates for investment products or services related to any financial
plan and/or Report, the investment products and services offered to client by TAS and/or its affiliates relationship
with its Clients will be governed exclusively by the terms and conditions of the account and/or products agreements
applicable to the products or services purchased by Client.
Key TAS, Affiliate and Third-Party Service Providers
Services Provided by TAS’ Investment Advisory Group (“IAG”)
Model Provider Services
TAS’ Investment Advisory Group designs and monitors on a continuous basis, model portfolios and asset
allocation models meeting the investment objectives provided by TAS, TAS Advisors and TB.
TAS IAG provides investment recommendations for each model portfolio or asset allocation model, initial and
ongoing due diligence with respect to sub-advisers, investment managers, model portfolio providers and their
models and mutual fund and ETF investments for all of TAS’ AMC Programs. IAG also provides research on
certain individual equity and fixed income securities that is used by TAS Advisors in advising and/or managing
Client portfolios in connection with the AMC Advisor Managed Programs.
IAG provides similar research services to TB related to its general trust department investment management services
and TIS for use in connection with its general brokerage services. Use of TAS’s IAG model provider services by TIS
and TB creates conflicts of interest in connection with the management of TAS AMC Program Accounts. See
Conflicts of Interest Models Created by IAG for Management of AMC Program Portfolios and Affiliate’s Usage
of the Models for Client Portfolio Management (TB and TAS Advisors) Section below.
In addition, IAG provides report updates and alerts related to its due diligence; creates or negotiates with third parties
related to advertising, marketing and research materials, monitors and updates as needed the capital market
assumptions and provides consultative services to TB on a regular or as needed basis.
AMC Truist Invest Program Investment Algorithm
TAS has contracted with a third-party investment research and financial technology firm to provide the investment
algorithm used by TAS to manage accounts invested in the AMC Truist Invest Program.
Envestnet Asset Management, Inc.
TAS has contracted with Envestnet Asset Management, Inc. a SEC registered investment adviser (“Envestnet” or
“Platform Manager”) for administrative services related to the AMC Programs including access to their platform
system that creates proposals based on TAS’ models and those of other investment managers pursuant to
agreements, ongoing monitoring of account positions to investments selected, submission of trade details to NFS
and performance reporting.
In the case of the AMC Fund Select Tactical, AMC Fund Select Tactical Focus, AMC Premier and Envestnet
Sentry Programs, the Platform Manager places trade orders with NFS on behalf of TAS via model updates
provided by TAS’ Investment Advisory Group (“IAG”) and model providers pursuant to an agreement with TAS
with pre-set initial transactions and periodic rebalancing triggers for transactions, where applicable.
In the case of the AMC Pinnacle Program and AMC Pinnacle – Sleeve Select, Envestnet acts as the overlay
manager and determines, in their sole discretion, the trading triggers from the initial investment through portfolio
updates and rebalancing triggers for transactions.
In the case of the AMC Fund Select Tactical and in certain situations, where Envestnet Managers are utilized, in
the AMC Pinnacle, AMC Pinnacle – Sleeve Select and Premier Programs, Envestnet is a co-adviser along with
TAS, and Envestnet conducts overlay management with respect to the trading within Client Program accounts.
Envestnet combines the securities into a composite model and calculates security weightings for each security in
the composite model. This procedure helps minimize the trading activity based on the security weights by
adjusting account holdings when trading events such as a request for cash from an account which results in sells
of overweight positions or an additional investment into an account which results in investments in underweighted
positions occur and helps to reduce portfolio costs, unnecessary trading and taxable events.
In the case of the AMC Truist Invest Program, TAS contracted with Envestnet for administrative services related
to the billing of AMC Truist Invest Program accounts.
See Envestnet’s Form ADV, Part 2A for more specific information.
Model Provider and other Research Services Provided to Truist Bank
• TAS has entered into an agreement with Truist Bank to also provide these services to Truist Bank for use
in its trust department asset management functions. See OTHER FINANCIAL INDUSTRY ACTIVITIES
AND AFFILIATIONS Section below.
• TB has sole and complete discretion to make investment recommendations and manage TB trust
department accounts in accordance with TAS’ IAG models. TAS’ IAG provides investment research and
model provider services to TB for its general use and not as recommendations to specific TB trust
department accounts. TB does not provide TAS with any individual Client information relating to Client
suitability or ongoing TB Client account reviews with respect to TB Client accounts invested in connection
with TAS’ IAG models and other investment research. TAS’ IAG updates research, model portfolio and other
investment and asset allocation models as requested by TB.
• Capital Market Assumptions
• TAS’ IAG designs, monitors and updates as needed on a continuous basis, the capital market assumptions
used by TAS and TB.
A conflict of interest exists when IAG research is shared with TAS affiliates TIS and TB for use in management of
their Client’s portfolios. See Conflict of Interest – Research Reports Created by IAG and Usage of Reports by
IAG and Affiliated Firms Section below for details; See also Conflict of Interest – Different Advice Section below
for details. See OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Section below regarding
agreements TAS has with TB and TIS related to Research and Other Advisory Services. Also see Conflicts of
Interest - Models Created by IAG for Management of AMC Program Portfolios and Affiliate’s Usage of the
Models for Client Portfolio Management (TB and TAS Advisors) Section below related to conflicts associated
with usage of research created and used by multiple affiliated firms and Advisors.
Sterling Capital Management, LLC (“Sterling”)
Sterling, provides TAS IAG with fixed income research and investment support on an as needed basis. IAG is
solely responsible for implementation of such research and investment support and is not required to follow
Sterling recommendations.
Truist Investment Services, Inc.
In addition to the TIS Brokerage Account requirement noted above, TIS acts as Non-Bank Custodian for IRA
accounts advised and/or managed by TAS and through NFS, acting as TIS’s agent, has custody of securities held
by AMC Program accounts.
TAS also selected the Truist Investment Services, Inc. Sweep Program’s TIS Level Rate Multibank Sweep Feature
(taxable accounts) and TIS Level Rate Single Bank Sweep feature, see Advisory Services – All AMC Programs
– Core Account – TIS Sweep Program. and creates conflicts of interest in connection with the management of
TAS AMC Program Accounts Conflicts of Interest – Truist Investment Services, Inc. Sweep Program Sections
below for details.
Truist Securities, Inc.
TAS’ affiliate, Truist Securities, Inc. (“TSI”), makes equity research reports available for TAS advisors for use in
the management of their Client’s portfolios. See Conflict of Interest – Research Reports Created by TSI and
Usage of Reports by TAS Section and Conflict of Interest – Different Advice Section below for details.
Institutional Capital Network, Inc. and CAIS
TIS has contracted with both Institutional Capital Network, Inc. (“iCapital Network”) and their affiliates and CAIS
and its affiliates and has granted TAS Advisors access to the iCapital Network and CAIS alternative investment
platforms, software and services for the AMC Allocation Plus and AMC Advise Programs.
iCapital Network and/or its affiliates and CAIS and its affiliates conduct the initial and on-going due diligence
(investment and operational) on private equity and hedge fund offerings available on their platform. TAS relies on
the due diligence provided by iCapital Network and CAIS related to the offerings available on either platform.
Fidelity Personal Trust Company, FSB
Fidelity Personal Trust Company, FSB (“FPTC”) offers Clients administrative trust services for AMC Programs,
Clients can request information related to the available services from their TAS Advisor.
Client Advisory Center (“CAC”)
TAS has established a centralized Client Advisory Center (“CAC”). The CAC consists of approximately 40 TAS
Financial Advisors (“CAC FAs”) who assist Clients in meeting their financial needs with financial planning and
access to TAS’ AMC Fund Select Tactical Focus or AMC Truist Invest Programs, where appropriate. The AMC
Fund Select Tactical Focus and AMC Truist Invest Programs is more fully described below.
CAC FAs work individually and as a team and the CAC’s primary advisor brochure supplement describes the.
CAC FAs working individually have their own advisor brochure supplements. Clients who wish to receive a copy
of a specific Advisor team member’s brochure supplement should contact the CAC at (844) 206-8900 and receive
this information free of charge.
Total TAS AMC Program Accounts and Assets Under Management as of December 31, 2023:
Accounts AUM
Discretionary 109,523 $ 48,528,680,981
Non-Discretionary 14,678 $ 12,841,175,564
124,201 $ 61,369,856,545
FEES
AMC Program accounts are charged a single asset-based fee (the “Program Fee”) that includes our ongoing
Client advice and service and the execution and custodial services of TIS and NFS except those charges that, as
described in the Other Fees and Charges Section below, will be paid by the Client. If Client elects to engage
Third-Party Model Provider(s) and Third-Party Managers in the connection with the management of Client’s
eligible AMC Program account(s), Client’s Program Fee will be corresponding increased by applicable Third Party
Model Provider and Third Party Manager fees. See Additional Model Provider or Investment Manager Fee,
below.
Additional fees and expenses can be charged in the AMC Annuity Program by the issuing company that are also
described in the Other Fees and Charges Section below. The Program Fee is tiered, based on the market value
of the Client's assets calculated on the last billing day of the previous quarter and paid in advance for accounts
opened prior to September 1, 2023. The Program Fee for new accounts established after that date is based on
the average daily asset balance over the prior quarter and paid in arrears. The Program Fee is either deducted
from the AMC Annuity contract, if the insurance company has obtained an IRS Private Letter Ruling, or an AMC
Program account (or designated TIS Brokerage Account for AMC Annuity Program Accounts) or Client may agree
to have the Program Fee deducted from another account owned by the same Client. If TAS is unable to collect
the Program Fee from any such separate account for any reason TAS shall be entitled to deduct the Program Fee
from the original account, or from any other AMC Account (or TIS Brokerage Account with the same registration
if in the AMC Annuity Program) without obtaining additional authorization from the Client.
How TAS Program Fees are deducted from the allocations of an annuity contract, specifically or proportionally is
determined by the specific insurance company and can vary. Clients should discuss the specific annuity’s process
with their TAS Advisor. The annuity contract value declines by the Program Fee amount deducted.
If no account is available to pay the Program Fee for any AMC Annuity Program account and the insurance
company has not obtained an applicable IRS private Letter Ruling, the Client’s AMC Annuity Program investment
advisory relationship will end. Options available upon termination of an AMC Annuity Program investment
management relationship are described below in the section “Termination of AMC Annuity Relationship”.
The Program Fee is negotiable and TAS enters into different fee structures with its’ Clients. AMC Program Fees
will vary from Client to Client as agreed with each Client by TAS, in its sole discretion. Factors considered by TAS
in making Program Fee modifications include, but are not limited to, the type and size of the Client’s account, the
range of services provided to the Client, and the total relationship between TAS and the Client in terms of assets
under management or supervision and the date the Client’s AMC Program account was established.
The following fees are, as applicable, charged in addition to the TAS Program Fee and apply to AMC Fund Select
Tactical, AMC Fund Select Tactical Focus, AMC Pinnacle, AMC Pinnacle – Sleeve Select, AMC Premier and
Sentry Programs:
• Additional Model Provider or Investment Manager Fee. In addition to the Program Fee, in the case of
AMC Fund Select Tactical, AMC Pinnacle, AMC Pinnacle – Sleeve Select, AMC Premier and Envestnet
Sentry Program accounts, if a Third Party Model Provider or a Third Party Manager is selected by the Client,
Client’s Program Fee will also include an additional Third Party Model Provider or Third Party Manager fee.
TAS will collect any applicable model provider or investment manager fee from AMC Program Client
accounts in the same manner as its Program Fee and separately remit payment to the applicable model
providers and investment managers.
• AMC Fund Select Tactical, AMC Pinnacle and AMC Pinnacle – Sleeve Select model portfolio provider fees
range from 35 to 75 basis points and AMC Premier, AMC Pinnacle – Sleeve Select SMA investment
manager fees range from 0 to 75 basis points.
• Envestnet Sentry Manager fees are more fully described in Envestnet’s Form ADV, Part 2A.
Additional Envestnet Administration Fee. This fee is included the model provider or investment manager fee.
Envestnet charges an administrative fee for the Envestnet Sentry Program and certain Third Party Model Provider
model portfolios in the AMC Fund Select Tactical Program. This fee ranges from two (2) to five (5) basis points of
the assets under management and is included in the manager fee.
Fee Schedule
Assets Under Management
TAS Maximum
Program Fee
First $0 - $100,000
2.25%
Next $100,001 - $250,000
2.20%
Next $250,001 - $500,000
2.15%
Next $500,001 - $1,000,000
2.00%
Next $1,000,001 - $2,000,000
1.85%
Next $2,000,001 - $5,000,000
1.75%
Next $5,000,001 - $10,000,000
1.65%
Next $10,000,001 - $25,000,000
1.50%
$25,000,001 and Over
1.45%
TAS Advisors are able to offer advisory services at fees lower than those noted above.
Please refer to each Third Party Model Provider and Third Party Manager’s Form ADV Part 2A Brochure for more
information on charges and expenses. See Additional Model Provider or Investment Manager Fee Section
above.
Annuities in AMC Annuity Program Accounts. For purposes of calculating the Program Fee, the annuity account
value is determined by the aggregation of the values of subaccounts or index segments and does not include any
additional rider or death benefit values.
AMC Annuity Fee Schedule
Assets Under Management
TAS Maximum
Program Fee
Up to $25,000,000
1.50%
Above $25,000,000
1.45%
TAS Advisors are able to offer advisory services at fees lower than those noted above.
Example of Overall Tiered Fee Calculation
AMC Allocation Plus, AMC Advise, AMC Fund Select Tactical and AMC Fund Select Tactical Focus Programs:
Portfolio of $1,000,000 would have an effective overall fee of 2.0925%:
First $100,000 at 2.25% would be an annual fee of $ 2,250
The next $150,000 at 2.20% would be an annual fee of $ 3,300
The next $250,000 at 2.15% would be an annual fee of $ 5,375
The remaining $500,000 at 2.00% would be an annual fee of $10,000
The total Program fee of $20,925 equates to 2.0925% of the total portfolio value of $1,000,000.
AMC Premier Program: Portfolio of $1,000,000 managed by a Third Party Manager would include the additional
manager fee (example 0.45%), thus raising the effective overall tiered fee to 2.5425%.
TAS base equity fee of $20,925 PLUS the Third Party Manager fee of $4,500 equals $25,425 or 2.5425%.
AMC Pinnacle or AMC Pinnacle – Sleeve Select Program Account with Multiple Sleeves
The Program Fee is based on the total value of the assets in the AMC Pinnacle or AMC Pinnacle – Sleeve Account
and includes an additional model provider or investment manager fee if a Third Party Model Provider or a Third
Party Manager is selected by the Client, See Additional Model Provider or Investment Manager Fee Section
above.
Example:
AMC Pinnacle total account asset value:
$500,000
SMA Sleeve – 3
rd
Party Manager
$300,000
TAS Program Fee plus 3rd Party Manager fee on $300,000
Advisor Managed Sleeve
$100,000
TAS Program Fee (no 3rd Party Advisor)
Strategist Sleeve
$100,000
TAS Program Fee plus 3rd Party Manager fee on $100,000
AMC Truist Invest
The Program Fee for the AMC Truist Invest Program is 0.85%. The Program Fee is not negotiable and investment
balances of multiple Client accounts are not aggregated for fee purposes.
Examples of the Fee Calculation:
An AMC Truist Invest relationship of $100,000 consisting of three accounts of $75,000 (individual taxable),
$20,000 (traditional IRA) and $5,000 (joint taxable) would have a Program Fee of 0.85% which equates to an
effective annual fee of $850 in aggregate and $638, $170 and $42 respectively.
Tax and Impact Overlay Services
Clients who elect the Tax and/or Impact Overlay management services provided by the Platform Manager related
to the AMC Pinnacle Program will be charged an additional fee based on the schedule below in addition to the
TAS base fee, manager or model fees. Clients should review the Platform Manager’s Brochure for more
information on fees related to Tax and/or Impact Overlay Services.
Clients who elect the Fidelity Investments® Charitable Gift Fund will be charged an additional fee paid
to Fidelity Charitable on the schedule below in addition to the TAS base fee and any model provider
or investment manager’s fees.
Giving Accounts Less than $5,000,000
Tiered Fee Schedule
Average Giving Account Balance Fee (Basis Points)
First $500,000 60 bps
Next $500,000 30 bps
Next $1,500,000 20 bps
Next $2,500,000 15 bps
Assets Under Management
Tax Overlay Service
$0 - $10,000,000
10 basis points
$10,000,001- $25,000,000
8 basis points
$25,000,001 and over
5 basis points
Giving Accounts with Balances of $5,000,000 or More: Flat Fee Schedule
Average Giving Account Balance Fee (Basis Points)
$ 5,000,000
- $ 9,999,999
19 bps
$10,000,000
- $19,999,999
17 bps
$20,000,000
- $34,999,999
15.5 bps
$35,000,000
- $47,999,999
13.5 bps
$48,000,000
- $74,999,999
12 bps
$75,000,000 and up
11.5 bps
Program Fees are pro-rated for accounts that are opened or closed during the quarter. Multiple Program accounts
held by the same Client or members of the Client’s immediate family (i.e., spouse, children, or parents) within the
same Program can be aggregated, at Client request and in the discretion of and upon approval of TAS, for
purposes of determining total amount of assets under management.
If Client invests or withdraws $10,000 or more in any AMC Program account after the inception of a calendar
quarter, the Program Fee for that quarter will be recalculated and pro-rated as of the day of the additional
investment or withdrawal.
Excluded and Unsupervised assets are not included in the Program Fee calculation; however, excluded assets
are included in account performance report calculations.
Additional areas Clients should consider when investing in an AMC Program where noted, where applicable:
• Asset Valuation. For purposes of the computation of the value of any securities or other investments in
an AMC Program account, securities listed on a national securities exchange will be valued, as of the
valuation date, at the closing price on the principal exchange on which they are traded. Shares of mutual
funds will be valued at their respective net asset values as calculated on the valuation date (or the most
recent net asset value if none is calculated on the valuation date) as determined by pricing sources
believed by TAS to be reliable. Any other securities or investments in an account will be valued by NFS
in a manner determined in good faith to reflect fair market value. Any such valuation should not be
considered a guarantee of any kind whatsoever with respect to the value of the assets in an account. NFS
typically uses a pricing service or other independent evaluator, as well as other independent sources, in
computing the value of securities. These values are believed to be reliable, but TAS will not verify the
accuracy of the information.
• Program Fee Valuation. The Program Fee is based on the value of the eligible Program Assets, including
cash and cash equivalents held in an AMC Program account. Excluded Assets (defined below) are certain
investments which may be included in the Account for reporting purposes. The Program Fee will not be
charged on Excluded Assets held in the account and the total market value of the Excluded Assets will
be deducted from the total market value of the account for determination of the billable value. Therefore,
the amount of Excluded Assets in an account could. result in the Client paying a higher fee percentage
due to the Program Fee Valuation decreasing below a schedule tier. As an example, a portfolio that
started with $500,000 at 2.15% where $300,000 was moved to an excluded position due to Client request
or for supervisory reasons, would incur a Program Fee of 2.20% at the next billing cycle after the assets
were transitioned to an excluded position.
• Privately Offered Securities. Valuations can lag a month or more and are received from the issuer’s third-
party administrator to the alternative investment vehicle, for directly offered investments or from iCapital
Network’s or CAIS’ fund administrator for those available on the iCapital Network and CAIS platforms.
The quarterly Program Fee calculation uses this data to calculate the Program Fee.
• Margin Use Increases Risk and the Program Fee. The Program Fee is based on the total amount of
assets in the Client’s account, including assets purchased using margin. If TAS uses margin in a Client’s
account, TAS and the Client’s Advisor each will receive additional compensation based on the increase
in the assets being managed. Although the Program Fee, as a percentage of assets under management,
will not change, the total assets on which this percentage is based will increase through the use of borrowed
funds, and, accordingly, the compensation paid to TAS, and the Client’s Advisor, will increase. In addition,
Clients who borrow funds will pay interest on the outstanding loan balance. TIS, the broker-dealer and
affiliate of TAS and Client’s TAS Advisor, who is dually registered with TIS, receive a portion of these fees
and interest. The use of margin borrowing creates conflicts of interest for TAS in connection with the
management of AMC Program accounts, See Conflicts of Interest – TIS Clearing Broker Credits
Section below for details.
There are risks associated with the use of borrowed funds for investment purposes. The decision to use
leverage from borrowed funds in a Client AMC Program account rests with the Client and should be made
only if the Client understands the risks of margin borrowing, the impact of the use of borrowed funds on
an account, and how the use of margin will affect the Client’s ability to achieve Client’s investment
objectives. Specifically, positive or negative performance of a margined account, net of interest charges
and other account fees, will be enhanced by virtue of using borrowed money. Thus, gains or losses in a
leveraged account will be greater than would be the case with an un-leveraged account. In addition,
Clients with margin accounts will need to deposit additional cash or collateral in their AMC Program
account if the value of the portfolio declines below the required loan- to-value ratio. If the Client cannot
provide the additional required collateral, NFS, the firm providing the margin loan, in its sole discretion, is
authorized to sell securities in the collateral account and other Client accounts to meet the margin
requirement. In these circumstances, the securities often will be sold into a market that is declining, so
the prices obtained for the liquidated securities are lower than in a stable or rising market. TAS and/or
Client’s TAS Advisor will not act as investment adviser to the Client with respect to the liquidation of
securities held in an account to meet a margin call and, as creditors, TAS and our affiliates, or NFS may
have interests that are averse to the Client. Clients electing to engage in margin borrowing will receive a
separate margin disclosure document from TIS. See Conflicts of Interest - TIS Clearing Broker Credits
Section below for details.
Householding for Program Fee Purposes. In all AMC Programs, except the AMC Truist Invest Program,
for purposes of determining the Program Fee charged to an account, the value of all accounts held by the
account owner and/or members of the same household (as determined by TAS) can be aggregated for
fee calculation purposes at the Client’s request and in the discretion and upon approval by TAS). AMC
Program Accounts accepted for householding will be treated as part of the same household on a case-
by-case basis as determined by TAS and will be combined for fee billing purposes. It is the Client’s
responsibility to request that AMC Program accounts be treated as part of the same household.
Householding of fees can provide fee breakpoint discounts if certain asset thresholds are met (see section
Fee Schedule above). Individual retirement accounts and other personal retirement accounts can be
aggregated for this purpose, but retirement plan accounts subject to the Employee Retirement Income
Security Act of 1974 (“ERISA”) cannot be aggregated.
• Accrued Interest. Accrued interest on fixed income securities will be included in the Program Fee
calculation.
• Excluded Assets. The billable value of your account does not include the value of excluded assets. The
impact of this lower billable value is that your account may be assigned a higher fee tier percentage.
• High Cash and Cash Equivalent Positions. Fees associated with portfolios invested in large positions of
cash and/or cash equivalents, including money markets, can be higher than the returns on these types of
investments.
The exact Program Fee each Client will pay is specified in the Client’s Statement of Investment Selection (“SIS”).
TAS is permitted to discount the Program Fee for employees of TAS and its affiliates in its sole discretion.
AMC Program accounts can, depending upon the investment products utilized, cost Clients more or less than
purchasing such services separately. Factors that can bear upon the cost of AMC Program accounts in relation
to the cost of the same services and/or investment products purchased separately can include, among other
things, the size and type of the account, the historical and expected size or number of trades for the account, the
mutual fund and other investment share classes made available to each type of account by the mutual fund
company or other investment provider and the number and range of supplemental services provided to the
account.
COMPENSATION
AMC Program Clients will not be charged a separate commission or other transaction charge for trades executed
through TIS and its clearing broker, NFS, instead such charges are included in the Program Fee and TAS will pay
TIS and NFS’ commissions and other transaction charges (as negotiated between TAS and TIS) for transactions
for made in connection with the management of AMC Program accounts. TAS or one or more of their affiliates
incurs additional expenses as the amount of trading in an AMC Program increase. As a result, TAS has a financial
interest in the number of trades recommended and has a financial incentive to seek to limit the extent of trading
activity of the AMC Programs. See Conflicts of Interest – Active Trading Section below.
AMC Program Clients will also incur other fees, expenses and costs associated with their account. See Other
Fees and Charges Section below.
A portion of the Program Fee compensates TIS for custody, clearance and settlement activities that are undertaken
by TIS even where an investment manager chooses to place the trade through a broker-dealer other than TIS.
When investment managers place trades through other broker-dealers, AMC Program accounts will be charged
additional fees, expenses and other costs by the applicable third-party broker-dealer. If a third-party broker-dealer
is utilized for trade execution services, the total net price paid for bonds or equities can be higher than the net
price which would have been paid if the transaction was undertaken through TIS. AMC Program investment
managers of fixed income portfolios have historically placed more trades through other broker-dealers than equity
investment managers. All Third Party Managers are responsible for best execution and control brokerage selection
on behalf of their Client accounts and Clients utilizing Third Party Managers should closely examine each Third
Party Manager tr’s Form ADV Part 2A brochure for information relating to each Manager’s best execution and
brokerage policies, including information relating to such investment manager’s receipt of “soft dollars” in
connection with its trading activities on behalf of customer accounts. For more information about the trading
practices of Third Party Managers, please refer to the “Important Information about the Trading Practices of
Independent Investment Managers and Envestnet in Certain Truist Advisory Services Managed Programs”
disclosure located on Truist Wealth’s website https://www.truist.com/wealth/tas-disclosure.
Where Client assets are held at another financial institution, custody, clearance, settlement and other charges
and fees imposed upon Client’s AMC Program account by such other financial institution are not included in the
Program Fee. As such, the costs and expenses will be more than if the Client assets were held at TIS, which
includes such costs and expenses in the Program Fee.
For the duration of each Client’s AMC Program investment advisory relationship with TAS, a portion of the
Program Fee received by TAS in connection with the management of each AMC Program account will be paid
the TAS Advisor associated with the Program account and other employees of TAS and its affiliates.
Depending upon trading volume and other services provided to Client accounts, TAS and the TAS Advisor
associated with each Client account can earn greater compensation if a Client invests in an AMC Program account
than if the Client were to instead open a brokerage account to buy individual securities. Therefore, if greater
compensation is expected to be received from an AMC Program account than from a brokerage relationship, TAS
and TAS Advisors have a financial incentive to recommend one of the AMC Programs rather than a brokerage
account relationship. See Conflicts of Interest – Advisory vs Brokerage Account Section below.
Depending upon applicable fee schedules, amounts invested in products offered and other services requested by
each Client, TAS and the TAS Advisor associated with each Client account can earn greater compensation if you
invest in an AMC Program than if a Client were to instead open a Truist Bank trust or investment management
account to manage your assets. Therefore, if greater compensation is expected to be received from an AMC
Program account than from a TB trust or investment management relationship, Advisors and TAS have a financial
incentive to recommend one of the AMC Programs rather than a TB trust or investment management relationship.
See Conflicts of Interest – Advisory vs Truist Bank Trust and Investment Management Accounts Section
below.
In addition, TB employees may refer qualified bank Clients to TAS Advisors for a one-time nominal fee of a fixed
dollar amount that is not contingent on whether the qualified Client referral results in any advisory activity or the
establishment of an investment advisory relationship. See Conflicts of Interest – Non-Deposit Retail Sales
(Networking) Agreement Section below.
Unsupervised Assets
Assets in certain Client AMC Program accounts can be classified as “unsupervised” for oversight reasons.
Unsupervised assets, although held in the same underlying brokerage account are not part of the managed
Program assets and therefore, no advice is given related to these assets, the assets are not subject to the Program
Fee and Unsupervised assets are not included in the performance calculations. Any unsupervised assets held in
an AMC Advise Program account are included in the Firm’s proxy voting process. See Section VOTING CLIENT
SECURITIES below for details.
New Client accounts enrolled in the AMC Programs (including existing TIS brokerage accounts) are required to
remove such “unsupervised” assets from their TAS advised TIS brokerage account and transfer such assets to a
separate TIS or other brokerage firm account. Any transfer of “unsupervised” assets to a separate brokerage
account will require affected Clients to execute applicable securities transfer documentation.
Excluded Assets
Assets in certain Client AMC Program accounts can be classified as “excluded” for a variety of reasons. Excluded
assets can be included in a model and will be included in Program performance calculations but will not be
included in the calculation of the Program Fee.
Other Fees and Charges
AMC Program Client accounts will incur separate fees or charges associated with odd-lot differentials, auction
fees, transfer taxes, electronic fund and wire transfer fees, SEC fees on NASDAQ trades, any other fees mandated
by law, certain fees in connection with the establishment or administration or termination of retirement or profit-
sharing plans or trust accounting, and any other charges for special services requested by Clients. Client accounts
holding shares of investment companies, including money market funds, closed-end funds, exchange-traded
funds, annuities and other investment products will incur additional fees, including, as applicable and disclosed in
each investment products prospectus, statement of information or other offering materials, certain advisory,
distribution, administration or other fees and expenses.
In addition to the Program Fees, Clients are subject to certain charges in connection with investments made
through the AMC Programs, including mutual fund/ETF advisory, distribution, early redemption or other fees.
Mutual funds (including money market mutual funds) and ETFs, or the advisers or principal underwriters of the
mutual funds or ETFs make payments to TIS, an affiliated company of TAS, from applicable share classes,
pursuant to a Rule 12b-1 distribution plan or other arrangement as compensation for distribution, shareholder
services, recordkeeping, or administrative services; these payments may be paid from the fund’s total assets or
may be paid by a fund’s adviser, distributor or their affiliates. TAS typically invests AMC Program Client accounts
in mutual fund and ETF share classes which do not pay 12b-1 fees to TIS. However, some mutual funds and
ETFs do not offer non-12b-1 share classes or do not contractually offer them to TAS Clients. TIS automatically
credits Client AMC Program accounts with an amount equal to any 12b-1 fees received by TIS as well as any other
fees for the distribution, shareholder services, recordkeeping or administrative services received during the period
an account is enrolled in an AMC Program. Each fund’s Rule 12b-1 distribution plan and other fee arrangements
will be disclosed to Client’s by TIS upon request and such fees are also disclosed in the applicable fund’s
Prospectus and Statement of Additional Information.
Client AMC Program accounts invested in these investment products will bear these fees and expenses. Each of
the fees discussed above is in addition to the Program Fee and will reduce Client investment returns by a like
amount.
TIS does not accept distribution, shareholder services, recordkeeping, or administrative services from mutual
funds, ETFs or similar products in connection with TAS accounts enrolled in the AMC Programs.
TIS receives and retains marketing support payments from investment product providers which can be
recommended and/or selected by TAS and TAS Advisors in connection with the management of the AMC
Programs. TAS evaluates all investment products offered to AMC Program Clients accounts using uniform criteria
and without regard to the receipt of marketing support payments by TIS. See Sections Conflicts of Interest -
Financial Service Vendor Continuing Education Sessions and Training and Educational Financial Support
below.
When selecting the share class for the mutual funds and ETFs, TAS does not, in all instances, select the share
class with the lowest fees that is available from the fund company due to the fund company not contractually
offering them to TIS for use by the AMC Program accounts. The Firm monitors fund families and holdings for
lower cost funds available on our platform on an ongoing basis. If a lower cost fund is available an exchange will
be made or the holdings will be excluded from billing.
TFC - Sterling Capital Management LLC Referral Agreement
Under the terms of TFC’s agreements with Guardian Capital Group Limited (“Guardian”) relating to TFC’s sale of
Sterling to Guardian, TFC may receive additional financial benefits if Sterling’s investment advisory, separate
account management, unified managed account model portfolio services, and other advisory services (“Sterling
Advisory Services”) are used in connection with TAS Program Accounts (other than Retirement Accounts
1
). See
Conflicts of Interest –__ TFC - Sterling Capital Management LLC Referral Agreement Section below.
Affiliated Multi-Manager Portfolios
GFO Advisory Services LLC (“GFO”), is a SEC registered investment adviser and an affiliate of TAS. GFO is the
general partner/managing member and/or investment adviser to a group of privately pooled investment vehicles.
Such vehicles are organized as domestic limited partnerships, limited liability companies, and offshore
corporations, (collectively, the “Affiliated Private Funds”). Affiliated Private Funds offered to AMC Advise and
AMC Allocation Plus Program Client accounts are evaluated by the Firm’s due diligence and research process by
the Investment Advisory Group (“IAG”) in the same manner as all other similar investments.
In addition, certain members of IAG serve as Portfolio Manager to GFO Advisory Services LLC’s Multi-Manager
Portfolios (“MMPs”). TAS and GFO share expenses related to the members of IAG who act as Portfolio Managers.
Offering Affiliated Private Funds to AMC Program Client Accounts creates conflicts of interest in connection with
TAS offering and management of the AMC Programs. See Conflict of Interest - GFO LLC, Section below for
details.
In the case of Retirement Account(s), TAS prohibits investment of Client accounts in Affiliated Private Funds. GFO
receives compensation for services provided to the Affiliated Private Funds that is separate, distinct and in addition
to, the Program Fee(s) earned by TAS. Clients can obtain additional information concerning Affiliated Private
Fund expense sharing by GFO, by contacting their TAS Advisor and/or consulting each Affiliated Private Fund(s)’
offering materials.
AMC Program Clients have the right to terminate their consent and authorization to the purchase or continued
retention of any Affiliated Fund(s) in Client’s AMC Program account any at any time (i) by terminating (or directing
TAS to terminate) the investment in the applicable Affiliated Fund(s), or (ii) by providing written notice to TAS of
Client’s intention that Client’s consent and authorization to invest Client’s AMC Program account in shares of
Affiliated Funds(s) set forth above has been terminated.
Mutual Funds and ETFs imposing Upfront Sales Charges Prohibited
TAS Advisors are prohibited from recommending or purchasing of shares of mutual funds or other pooled
investment vehicles such as ETFs with an upfront fee for AMC Managed Program accounts. In addition, if shares
of such investments are transferred to an AMC Managed Program account, a lookback for a period of 360 days
after shares were purchased by the Client in a transaction which was executed by TIS and Client’s TIS Registered
Representative is conducted and Client accounts are refunded any commissions generated during that period,
depending on circumstances.
AMC Annuity Program
Variable annuity contracts purchased in connection with AMC Annuity Program accounts charge Mortality,
Expense & Administration (“M&E” or “M&E&A”) fees and other fees assessed by the annuity provider. Any
additional riders purchased in connection with a variable annuity contract are typically subject to an additional fee.
All variable annuity fees and expenses are assessed against the contract’s account value. M&E fees and other fees
related to an annuity contract are explicitly outlined in each product’s prospectus. Investment in the insurance
company’s subaccounts will be subject to additional fund management and other expenses and fees. Each annuity
1
AMC Program accounts which are either (1) qualified plans subject to the prohibited transaction requirements of
the Employee Income Security Act of 1974 or (2) managed individual retirement accounts or similar retirement
accounts subject to similar prohibited transaction requirements of §4975 of the Internal Revenue Code (each and
together “Retirement Account(s)”).
product’s prospectus should be thoroughly reviewed for a full explanation of the assessment of all fees and
expenses associated with any investment in a variable annuity contract. All fees assessed by the annuity provider
are in addition to any Program Fees charged by TAS and reduce investment returns associated with the investment
by a like amount.
ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS
AMC Program Account Requirements and Types of Clients
Program
Minimum Funding Amount*
TAS Advisor Managed Programs
AMC Allocation Plus
$100,000
AMC Advise
$ 50,000
AMC Annuity
$ 50,000
TAS and Third-Party Managed Programs
AMC Truist Invest
$ 5,000**
AMC Fund Select Tactical
$ 50,000
AMC Fund Select Tactical – Focus***
$ 10,000
AMC Pinnacle/AMC Pinnacle – Sleeve Select
$ 50,000
AMC Premier
$100,000 (varies by Manager)
Envestnet Sentry
$100,000 (varies by Manager)
* AMC Program Accounts established and not funded at the minimum funding requirement within 90 days
may be reclassified as standard unmanaged full-service commission based TIS brokerage accounts. TAS
retains the right to waive or increase or decrease the minimum investment amounts for each Program upon written
notice to affected Clients.
** AMC Truist Invest Program. If an AMC Truist Invest Program account relationship falls below the minimum
amount, TAS may terminate the Program Account. While TAS has structured the AMC Truist Invest Program to
be broadly applicable to many Clients, it may not be appropriate for certain Clients that:
• are already in retirement and drawing down savings;
• desire more frequent account reviews for trading opportunities;
• have a very short (less than five years) investment horizon, a significantly high tolerance for market risk,
or a desire to invest significantly in alternative asset classes;
• do not wish to delegate investment management to an automated algorithmic manager;
• wish to work directly with an individual portfolio manager (applicable to AMC Truist Invest Program
accounts);
• have especially complex investment objectives and needs as Client’s current investments consist of
illiquid securities, annuities, and/or extremely low basis securities; and/or
• have limited or no access to the internet and other necessary technology because the AMC Truist Invest
Program delivers disclosures and other information electronically.
If the AMC Truist Invest Program is inappropriate for a Client’s needs or if a Client prefers a non-automated, non-
algorithmic advisory service and greater ability to control and direct the investment of Client’s assets, Client should
consider the other advisory services and programs offered by TAS and described in this brochure. In addition,
Clients should consider a standalone TIS brokerage account, in which Clients pay commissions per trade rather
than a periodic asset-based fee relationship.
Should a Client determine that AMC Truist Invest Program is appropriate notwithstanding the above
considerations, Client must keep in mind that AMC Truist Invest Program is structured to assist a Client in reaching
their selected account goal(s) and is meant to be a component of their overall investment strategy and not the
Client’s sole investment strategy. The AMC Truist Invest Program’s projections and decisions are limited in scope
to the questions asked and information provided by the Client when a Client opens a AMC Truist Invest Program
investment advisory account.
As AMC Truist Invest Program does not provide comprehensive financial planning, there may be additional
relevant information or other financial circumstances that AMC Truist Invest does not consider (e.g., Client’s debt
obligations or other ongoing financial obligations, extraordinary expenses such as college tuition, personal or
family medical expenses, etc.) that could impact Client’s financial situation and therefore make AMC Truist Invest
and its investment advisory services unsuitable. Clients are urged to carefully consider the AMC Truist Invest
Program’s costs, benefits and risk and other information below before opening an AMC Truist Invest investment
advisory account and beginning to invest.
TAS reserves the right to accept, reject or renew any Client for AMC Truist Invest Program accounts.
AMC Truist Invest Program Clients must be permanent legal residents of the United States. Clients are not
required to have a preexisting relationship with TAS, TIS or Truist Bank to participate in the AMC Truist Invest
Program.
*** AMC Fund Select Tactical Focus. Plan Sponsor Consulting accounts invested in the AMC Fund Select
Tactical Focus Program are exempt from the minimum funding requirement but must meet any Manager minimum
investment thresholds.
The AMC Programs are made available to individuals, corporations and other business entities, pension and
profit-sharing plans, charitable organizations and not-for-profit organizations. TAS reserves the right to accept,
reject or renew any Client for any AMC Program. AMC Programs products and services are not guaranteed by
Truist Bank, any other bank, or any subsidiary of Truist Financial Corporation. Products recommended by TAS
are not insured by the Federal Deposit Insurance Corporation with the exception of investments of certain
Brokered CDs and the Truist Investment Services, Inc. Sweep Program, subject to applicable FDIC insurance
limits as described in applicable TIS brokerage account disclosures.
PORTFOLIO MANAGER AND MODEL MANAGER SELECTION AND EVALUATION
TAS Advisor Managed Programs
TAS advisors serve as portfolio managers for Client accounts in the AMC Advise program.
The AMC Allocation Plus and AMC Annuity Programs are Client directed and advisors do not have the
discretionary authority to implement changes without Client consent.
TAS and Third-Party AMC Managed Programs
TAS’ IAG identifies and conducts initial and ongoing investment due diligence with respect to investment
managers and model providers, affiliated and unaffiliated, for inclusion in the AMC Premier Program and the
Strategist and SMA Sleeves in the AMC Pinnacle or AMC Pinnacle – Sleeve Select Program. Approved
investment managers and model providers enter into model portfolio agreements and investment management
agreements with TAS.
IAG conducts reviews of mutual funds, Third Party Managers and other investment vehicles utilized in the AMC
Managed Programs and portfolios and determines which to include and if and when to remove a fund, investment
vehicle or other investment vehicle. A representative from IAG presents reports at the TIS/TAS Product and
Platform Committee meeting related to Model Portfolio Providers, Third Party Managers and other investment
vehicle changes made by IAG.
IAG also creates and maintains model portfolios and asset allocation strategies utilized in the AMC Fund Select
Tactical, AMC Fund Select Tactical, Focus, AMC Pinnacle, AMC Pinnacle – Sleeve Select and the AMC Premier
programs. A representative from IAG periodically presents a new or modified model portfolio and/or asset
allocation strategy to the TIS/TAS Product and Platform Committee for review and approval. The TIS/TAS Product
and Platform Committee also reviews and approves or rejects any services provided by IAG to any portfolio offered
to Clients in connection with the AMC Managed Programs.
The TIS/TAS Product and Platform Committee of TAS oversees these Programs and reviews the performance
information and due diligence and other information provided by IAG.
Envestnet, acts as co-adviser, overlay manager and/or Manager with respect to the Envestnet Sentry Program
and the Fixed Income SMA Sleeve in the AMC Pinnacle or AMC Pinnacle – Sleeve Select Program identifies and
along with TAS’ IAG conducts initial and ongoing investment due diligence with respect to investment managers
and model providers for inclusion in those Programs. Approved investment managers and model providers enter
into model portfolio agreements and investment management agreements with Envestnet.
TAS provides portfolio management for AMC Fund Select Tactical, AMC Fund Select Tactical Focus, certain AMC
Pinnacle and, AMC Pinnacle – Sleeve Select portfolios, certain AMC Premier portfolios and its automated
investment Program, the AMC Truist Invest Program, at the Firm level. The Firm does not manage any other
investment advisory programs; its Advisors, however, do manage Client accounts either on a discretionary or non-
discretionary basis within the AMC Advise, AMC Allocation AMC Pinnacle and AMC Pinnacle – Sleeve Select
Programs.
TAS Advisors manage Client assets in both the AMC Advise and AMC Allocation Plus Programs. The Firm
establishes guidelines for each Program. In addition, advisors in the AMC Advise Program are screened by the
Firm prior to approval to participate in the Program. Although the review is similar to the review conducted on
Third Party Managers, AMC Advise advisor reviews are completed by key management personnel not IAG. In
addition, IAG conducts annual reviews either in person or via email or phone, while AMC Advise and AMC
Allocation Plus advisor’s accounts are monitored on a daily basis.
TAS Advisors who manage AMC Allocation Plus and/or AMC Advise Program portfolios can also manage Advisor
managed sleeves in the AMC Pinnacle and/or AMC Pinnacle – Sleeve Select Program and when they do, trades
effected in the AMC Allocation Plus or AMC Advise portfolios are sent directly to NFS, the clearing firm for TIS;
however, those trades in the AMC Pinnacle and/or, AMC Pinnacle – Sleeve Select Program are entered by
Envestnet, who has overlay responsibilities related to all the trades in the AMC Pinnacle and/or AMC Pinnacle –
Sleeve Select Program. The trades in AMC Truist Invest Program accounts are sent directly to NFS. These
differences can result in similar trades executing at different times and at different prices for the same security.
Generally, those trades in the AMC Allocation Plus and AMC Advise portfolios are executed before those in the
AMC Pinnacle and/or AMC Pinnacle – Sleeve Select Advisor managed sleeves and/or the AMC Truist Invest
portfolios.
CONFLICTS OF INTEREST
Investment advisory fees and other expenses incurred by AMC Program accounts may be more or less than
similar services provided by other firms. TAS Advisors recommending that a Client invest in the AMC Programs
accounts receive compensation based on the amount of assets under management within a Client’s Program
Account and as Program Account assets increase, the amount of compensation received by a TAS Advisor will
also increase and therefore TAS Advisors have a financial incentive to recommend AMC Program accounts and
other services offered by TAS and its affiliates rather than similar products services offered by other investment
firms. This creates a conflict of interest and TAS addresses this conflict of interest by disclosing it to its Clients
and by requiring TAS Advisors’ supervisors, or designees, to review each AMC Program account at account-
opening to determine that opening an AMC Program account is in the best interest of each Client and their unique
investment objectives and financial circumstances in conformity with TAS’ fiduciary duties to Clients as codified in
the Advisers Act and regulations thereunder
In offering and managing the AMC Programs, TAS has additional conflicts of interest which are more fully
described below.
Advisory Annuity vs. Transactional Annuity. Depending upon the level of a Client’s investment activity and
corresponding annuity fees, TAS and your Advisor, in the case of the AMC Annuity Program, it is possible that
TAS and Client’s TAS Advisor will earn greater compensation from accounts enrolled in this Program than if a
Client instead elected a commission based transactional annuity relationship. If anticipated transactional annuity
commission compensation is less than the AMC Annuity Program Fee, TAS and Client’s TAS Advisor will have a
financial incentive to recommend the AMC Annuity Program instead of a commission based transactional annuity
relationship. TAS addresses this conflict of interest by disclosing it to its Clients and by requiring TAS Advisors’
supervisors, or designees, to review each account at account-opening to determine that each recommendation to
a Client to open an AMC Annuity Program account is in the best interest of each Client and their unique investment
objectives and financial circumstances in conformity with TAS’ fiduciary duties to Clients as codified in the Advisers
Act and regulations thereunder.
Advisory vs. Brokerage Accounts. Depending upon the level of a Client’s investment activity and corresponding
brokerage commissions TAS and your Advisor in the case of each of the AMC Programs, it is possible that TAS
and Client’s TAS Advisor will earn greater compensation from accounts enrolled in an AMC Program than if a
Client instead elected a brokerage relationship and purchased individual securities. If anticipated brokerage
compensation is less than the applicable AMC Program Fee, TAS and TAS Advisors will have a financial incentive
to recommend one of the AMC Programs instead of a brokerage relationship. TAS addresses this conflict of
interest by disclosing it to its Clients and by requiring TAS Advisors’ supervisors, or designees, to review each
AMC Program account at account-opening to determine that opening an AMC Program account is in the best
interest of each Client and their unique investment objectives and financial circumstances in conformity with TAS’
fiduciary duties to Clients as codified in the Advisers Act and regulations thereunder.
Advisory vs. Truist Bank Trust and Investment Management Accounts. If anticipated revenue from a Truist Bank
trust or investment management account is less than a Client’s anticipated AMC Program Fee, TAS and TAS
Advisors who are also Truist Bank employees, will have a financial incentive to recommend one of the AMC
Programs instead of a Truist Bank trust or investment management relationship. Therefore, if anticipated Truist
Bank trust department compensation is less than the applicable AMC Program Fee, TAS and TAS Advisors will
have a financial incentive to recommend one of the AMC Programs instead of a Truist Bank trust or investment
management relationship. TAS addresses this conflict of interest by disclosing it to its Clients and by requiring
Advisors’ supervisors, or designees, to review each account at account-opening to determine that opening an
AMC Program account is in the best interest of each Client and their unique investment objectives and financial
circumstances in conformity with TAS’ fiduciary duties to Clients as codified in the Advisers Act and regulations
thereunder.
Clients with assets on both the TB and TAS platforms will not have assets combined for fee discounts on either
platform, each entity and its programs are separate and distinct from each other.
Block Trades.
• AMC Advise - Orders for the same security entered on behalf of more than one Client may be aggregated
(i.e., “blocked”) for execution purposes. The aggregation of trades will only be done when it is in the best
interests of all participating Clients and generally seeks to obtain a more advantageous net price.
Subsequent orders for the same security entered during the same trading day may be aggregated with
any previously unfilled orders; filled orders shall be allocated separately from subsequent orders. All
Clients participating in the aggregated order will receive the average price of all transactions effected to
fill the order. The average price may be higher or lower than the price an individual Client may have
received if the transaction was executed outside of the block order.
• Third Party Managers in AMC Program Accounts - Investment managers are permitted to direct block
trades to TIS for execution; however, they are also permitted to execute trades at other brokerage firms.
Each investment manager’s block trading policies are contained in such investment manager’s Form ADV
Part 2A brochure. Clients enrolled in the AMC Premier, AMC Pinnacle and AMC Pinnacle – Sleeve Select
Programs who are selecting or have selected an investment manager to manage accounts enrolled in
these Programs should carefully examine each applicable investment manager’s Form ADV Part 2A
brochure to determine each investment manager’s policies and procedures relating to block trading.
• The Algorithm used in the AMC Truist Invest Program does not aggregate trading orders prior to sending
the orders to NFS for execution.
Business Conflicts. TAS and its affiliates, including Truist Bank, Envestnet and their respective affiliates do
business with companies, managers and mutual funds offered to AMC Program accounts by TAS. Furthermore,
TAS, Truist Bank and their affiliates and other Client accounts, advised and/or managed by such entities typically
also hold trading positions (long or short) in, the securities of such companies and have business relationships
with such companies, managers or funds. Therefore, TAS, Truist Bank, Envestnet and their affiliates have conflicts
of interests that could affect the objectivity of TAS investment research and advice provided to Client accounts
enrolled in the AMC Programs. TAS addresses these conflicts of interest by disclosing them to its Clients and by
supervising the activities and recommendations made by TAS’ IAG with supervisory review by its TIS/TAS Product
and Platform Committee for conformity with TAS’ fiduciary duties to Clients as codified in the Advisers Act and
regulations thereunder.
Different Advice.
TAS’ Investment Advisory Group: TAS’ IAG provides research and models similar to the models IAG utilizes
connection with the AMC Programs to TAS Advisors managing Advisor managed AMC Programs. TAS Advisors
separately managing AMC Programs can give different advice, take different action or hold or deal in different
securities than those contained in model portfolios and research provided by TAS’ IAG. In addition, the advice
given by TAS affiliates utilizing their own research and models and/or third-party research and models can be
different than that given by IAG to TAS for use in the management of AMC Program accounts. TAS addresses this
conflict of interest by disclosing it to its Clients and by sharing changes to its model portfolios, other models
research, models and other investment research among all recipients of this information its Clients simultaneously
or as closely in time as possible, including TAS, TAS, Advisors, TIS and TB in conformity with TAS’ fiduciary duties
to Clients as codified in the Advisers Act and regulations thereunder.
Truist Securities, Inc. TSI provides equity research that TAS Advisors can utilize in the management of Advisor
managed AMC Programs. TAS Advisors separately managing AMC Programs can give different advice, take
different action or hold or deal in different securities than those contained in research reports available from TSI.
In addition, the advice given by TAS Advisors utilizing their own, IAG’s and/or third-party research can be different
than that given by TSI for use in the management of AMC Program accounts. TAS addresses this conflict of
interest by disclosing it to its Clients in conformity with TAS’ fiduciary duties to Clients as codified in the Advisers
Act and regulations thereunder.
Business Incentive Programs. For the duration of each AMC Program investment advisory account relationship,
TAS Advisors are compensated in part by Business Incentive Programs (“BIP”) which reward Advisors with a
percentage of the revenue TAS receives from the AMC Program accounts associated with each TAS Advisor. In
addition, TAS Advisors can also receive credit towards their qualifying production (through both one-time cash
payments or increased payout rates) for referrals to other parts of the bank for services offered to those Clients.
For select consumer securities backed loans or lines of credit arranged with the bank are also eligible to receive
25 basis points (annualized) applied against their average monthly payout. This presents a potential conflict of
interest as the TAS Advisor will continue to receive a fee based on assets in an AMC Program Account. TAS
addresses this conflict of interest by disclosing it to its Clients and by requiring TAS Advisors’ supervisors, or
designees, to review each account at account-opening to determine that opening an AMC Program account is in
the best interest of each Client and their unique investment objectives and financial circumstances in conformity
with TAS’ fiduciary duties to Clients as codified in the Advisers Act and regulations thereunder.
Financial Service Vendor Continuing Education Sessions. TAS Advisors are permitted to participate in investment
product vendor sponsored continuing education sessions (whether or not the product or service provided by the
vendor can be recommended to TAS Clients or prospective Clients). The participation of TAS Advisors in these
education sessions could potentially encourage TAS and/or TAS Advisors to promote and recommend products
from event sponsors, thus creating a conflict of interest. TAS addresses this conflict of interest by disclosing it to
its Clients and by requiring TAS Advisors’ supervisors, or designees, to monitor AMC Program accounts and by
supervising the activities and recommendations made by IAG with supervisory review by TIS/TAS Product and
Platform Committee for conformity with TAS’ fiduciary duties to Clients as codified in the Advisers Act and
regulations thereunder.
GFO Advisory Services LLC – GFO Private Funds. TAS has identified GFO’s Private Funds as presenting conflicts
of interest in connection with TAS’s offering and management of the AMC Programs in that GFO, a TAS affiliate
has an agreement with TAS for services, including Portfolio Management of GFO’s Private Funds, where TAS and
GFO share expenses related to certain TAS IAG members and GFO receives compensation for services provided
to the Affiliated Private Funds that is separate, distinct and in addition to, the Program Fee(s) earned by TAS.
TAS addresses this conflict of interest by disclosing it to its Clients and mitigates this conflict of interest by
evaluating GFO’s Private Funds through the TAS IAG due diligence and research process in the same manner as
all similar investments. TAS further mitigates this conflict of interest by granting Clients the continuing right to
terminate their consent and authorization to the purchase or continued retention of any Affiliated Private Fund(s)
in Client’s AMC Program account any at any time (i) by terminating (or directing TAS to terminate) the investment
in the applicable GFO Private Funds, or (ii) by providing written notice to TAS of Client’s intention that Client’s
consent and authorization to invest Client’s AMC Program account in GFO’s Private Funds has been terminated.
Certain AMC Program accounts are retirement accounts which are either (1) qualified plans subject to the
prohibited transaction requirements of the Employee Income Security Act of 1974 or (2) individual retirement
accounts or similar retirement accounts subject to similar prohibited transaction requirements of the Internal
Revenue Code (each and together “Retirement Account(s)”). In the case of Retirement Account(s), TAS prohibits
AMC Program accounts from investing in GFO’s Private Funds.
Gifts and Gratuities. TAS Teammates give and/or receive non-cash gifts and/or entertainment to or from Clients,
centers of influence, other Teammates and/or service providers which could potentially affect or have an
appearance of affecting the Teammate's judgment or the manner in which they conduct business. TAS addresses
these conflicts by prohibiting Teammates from giving or receiving any non-cash gift of more than $100 annually
and requiring Teammates to report all gifts given and/or received quarterly in conformity with TAS' fiduciary duty
to Clients as codified in the Advisers Act and regulations thereunder.
Incentive and Other Compensation Provided to TAS Advisors:
In the conduct of its business TAS’s affiliate, TIS maintains employment productivity standards and incentive
compensation programs which are intended to reward productive employees, including TAS Advisors who are
also registered with TIS (“Truist Advisors”); encourage Truist Advisors to present investment and other financial
products offered by TIS, TAS and their respective affiliated companies (“Affiliates”) to their Clients; encourage
Truist Advisors to remain with the Firm; aid in the recruitment of Truist Advisors and in general promote the
successful financial performance of TIS, TAS and their Affiliates. The terms of these incentive programs vary
among Truist Advisors and not all representatives are offered the opportunity to participate in all of the incentive
programs described below.
• Recruiting and Retention Loans: Recruiting and Retention Loans are an incentive compensation program
offered to certain Truist Advisors and are typically structured as an initial lump sum loan (or series of loans)
that is extended to the applicable Truist Advisor in the form of loan agreements, bonus agreements and
promissory notes. Under the terms of these agreements, the Truist Advisor is required to pay-back the
loan on a periodic basis for a set period of time, typically over a period of years; but the Truist Advisor’s
loan payments are reimbursed by TIS and/or TAS in the form of bonus payments while the Truist Advisor
remains employed by TIS. TIS and /or its affiliates maintain the right to accelerate the term of the incentive
loans and, in almost all cases, TIS and /or its affiliates demand immediate repayment of the recruiting and
retention loans upon the voluntary or involuntary termination of a TIS representative’s employment with
TIS.
New Accounts Bonus: Some newly hired Truist Advisors also receive an incentive bonus based on the value of
new accounts opened with the Firm within a fixed period of time following their employment date with the Firm.
However, this incentive bonus is based solely upon the asset value of new accounts opened with TIS and/or TAS
and is not linked to revenue production associated with the Truist Advisor’s new accounts.
• Revenue Based Bonuses and Compensation Percentage Increases: Truist Advisors receive bonuses for
meeting overall revenue production targets which are based upon the aggregate revenue the Truist
Advisor generates for TIS, TAS and their Affiliates in connection with purchases of investment products,
investment advisory services and other financial products offered by TIS, TAS and their Affiliates by the
Truist Advisor’s Clients. This compensation increases in percentage amounts as the amount of the
revenue generated by the Truist Advisors’ associated Client base increases.
• Minimum Revenue Production Standards: Each Truist Advisor’ employment with TIS and TAS is also
dependent upon meeting minimum revenue production standards relating to revenue generated by the
Truist Advisors’ Client’s purchases of investment products, investment advisory services and other
financial services offered by TIS, TAS and their Affiliates. Qualifying revenue includes brokerage
commissions, investment advisory compensation and other revenue received by TIS, TAS and their
Affiliates.
• Conflicts of Interest Associated with Incentive and Other Compensation Provided to TAS Advisors: TIS’
incentive programs and minimum production standards encourage Truist Advisors to remain employed by
TIS and TAS and to recommend TIS’s brokerage products and services, TAS’s investment advisory
services and other financial services and products offered by their Affiliates in order to increase the
applicable Truist Advisor’s revenue based compensation and /or to remain employed by TIS and TAS,
and therefore create conflicts of interest in connection with Truist Advisor’s recommendations of TIS and
TAS account relationships and products and other financial services and products offered by TIS, TAS
and their Affiliates to their Clients.
Because Truist Advisors’ incentive compensation programs (other than the New Accounts Bonus
described above) and minimum production standards are closely tied to the amount of revenue generated
for TIS, TAS and their Affiliates by each Truist Advisor, Truist Advisors have a financial incentive to
recommend higher cost products and services, which can provide higher amounts of compensation to
TIS, TAS and their Affiliates, rather than other comparable products and services to their Clients. The
financial incentives to recommend only investment products which provided compensation to TIS, TAS,
and their Affiliates and the applicable Truist Advisor and to recommend higher cost investment products
can encourage Truist Advisors to make investment recommendations for reasons other than a Client’s
specific investment needs and therefore creates a conflict of interest in connection with Truist Advisors’
investment recommendations to their Clients.
In addition, the New Accounts Bonus and other programs described above create compensation-based
incentives for Truist Advisors who were previously employed by other firms to encourage Clients of their
former firm to open new accounts with TIS and TAS and therefore Truist Advisors have a financial conflict
of interest in making such recommendations.
In order to mitigate these conflicts of interest, TIS and TAS disclose them to their Clients; have structured
the New Account’s Bonus program to be based only upon the asset value of new accounts opened with
TIS (and not the revenue generated with respect to such accounts) and provides former customers
solicited by newly hired representatives with additional disclosures in connection with such solicitations.
TIS also addresses revenue based conflicts of interest by structuring its incentive programs and minimum
production standards in a manner based upon overall revenue generated which is not linked sales of
specific investment products or services, by prohibiting sales contests and the sales of certain investment
products and by supervising Truist Advisors’ brokerage, investment advisory and other investment product
recommendations, including but not limited to, the recommendations of managed investment advisory
program accounts sponsored by TAS, in accordance with applicable laws, regulations and other
applicable requirements.
Models Created by IAG for Management of AMC Program Portfolios and Affiliate’s Usage of the Models for Client
Portfolio Management (TB and TAS Advisors). Truist Bank trust department accounts and TAS Advisor managed
AMC Program accounts utilizing models created by IAG for management of TAS AMC Program portfolios can
independently elect to modify IAG models in allocation percentage and/or security selection with respect to
accounts they separately manage. Such discretion will cause Truist Bank trust department accounts and TAS
Advisor managed AMC Program accounts to have differing performance and portfolio positions than the IAG
models. Further, even if the IAG models used by TB and TAS Advisors are the same as those created and used
by IAG, the timing of trade entry will differ due to separate decision making and order entry systems used by each
TAS, TB and each TAS Advisor resulting in differences in performance due to the possible differing of trade
execution prices, resulting in either a lower or higher share costs due to market conditions at the time of order
execution. Changes to IAG model portfolios, models and other investment research are distributed by TAS’ IAG
to TAS, TAS Advisors, TB and TIS simultaneously, or as closely in time as possible. Each firm (and TAS Advisor),
however, is responsible for implementing IAG updates in accordance with their internal systems and procedures.
TAS addresses this conflict of interest by disclosing it to its Clients and by simultaneously sharing changes to its
model portfolios, models and other investment research among TAS, TAS Advisors, TB and TIS in conformity with
TAS’ fiduciary duties to Clients as codified in the Advisers Act and regulations thereunder.
Non-Deposit Retail Sales (Networking) Agreement. TAS has entered into a Non-Deposit Retail Sales (Networking)
Agreement with Truist Bank. Under this agreement, unregistered TB employees can refer qualified bank Clients
to TAS Advisors (if included in applicable TB employee financial incentive programs) for a one-time nominal fee
of a fixed dollar amount that is not contingent on whether the qualified Client referral results in any advisory activity
or the establishment of an investment advisory relationship with TAS. In addition, this agreement allows
unregistered bank employees to receive contingent compensation for referrals of high-net-worth individuals
(prospects with investable assets greater than $5,000,000) which will be received by the referring bank employee
only if TAS investment advisory services are purchased. Solicitation arrangements such as this agreement give
rise to conflicts of interest because the referring party has a financial incentive to introduce new investment
advisory Clients to TAS. TAS addresses this conflict of interest by disclosing it to its Clients and by requiring
Advisors’ supervisors, or designees, to review each AMC Program account at account-opening to determine that
it is in the best interest of each Client and their unique investment objectives and financial circumstances in
conformity with TAS’ fiduciary duties to Clients as codified in the Advisers Act and regulations thereunder.
Furthermore, as required by the agreement, TB supervises its unlicensed employee investment referrals in
accordance with the requirements of Federal Reserve Board Regulation R, Exceptions for Banks from the
Definition of Broker in the Securities Exchange Act of 1934.
Non-Public Information. In the course of commercial and investment banking or other activities, TB, TAS, TIS and
other TFC affiliates and Third Party Managers and each of their respective affiliates and agents can from time to
time acquire confidential or material nonpublic information that can prevent them, for a period of time, from
purchasing or selling particular securities for AMC Program Client accounts. in order to avoid possible violation of
federal and state securities laws and regulations. This inability to trade can adversely impact the investment
performance of Client accounts. TAS addresses this conflict of interest by disclosing it to its Clients and acting in
conformity with federal and state securities laws and regulations.
Other Investment Products Available. TAS does not offer all available securities, investment products, model
portfolios and other investment models to the AMC Program accounts. Instead, TAS limits securities investment
products, model providers and investment managers to those TAS (or a TAS Advisor approved in connection with
AMC Advise Program) has reviewed and deemed to be eligible investments for each of the AMC Programs.
Additional securities, investment products, model portfolios and other investment models can be offered to AMC
Program accounts by other available investment model providers and investment managers.
Third party Investment managers can offer to the public other investment products such as mutual funds or ETFs
with similar investment styles and holdings as those investment products offered through the AMC Programs.
TAS and other model providers can also offer the same or similar model portfolios to the public. Such investment
products, model portfolios and other investment models can be offered at differing fees and charges that can be
higher or lower than the Program Fees charged by TAS in connection with the Programs and the investment
manager and model portfolio provider fees charged to AMC Program accounts. For example: a separate account
investment product and a mutual fund investment product sometimes utilize the same investment manager and
investment strategy but involve different minimum investment amounts and fees. It is possible that an AMC
Program account can include a mutual fund investment product even where a similar but lower cost separate
account investment product is available to AMC Program accounts and TAS will not in all cases, due to tax basis
or other considerations, sell the applicable mutual fund and reinvest the applicable account in the comparable
separate account investment product, even if a Client’s assets increase to above the minimum investment amount
required for the separate account investment product. In addition, TAS affiliates, including TIS and the trust
department of Truist Bank, are authorized to offer investment products that are not offered in connection with the
AMC Programs. TAS addresses this conflict of interest by disclosing this limitation to its available investment
products and services offered to AMC Program accounts to its Clients and acting in conformity with TAS’ fiduciary
duties to Clients as codified in the Advisers Act and regulations thereunder.
Outside Business Activities. Outside business activities could give rise to an appearance of competing interests.
TAS addresses these conflicts of interest by requiring Teammates to request approval from their Principal Manager
prior to participating in any outside business activity. In addition, TAS Advisors are required to disclose those
outside business activities that represent 10% or more of their time or revenue in their brochure supplement in
conformity with TAS’ fiduciary duty to Clients as codified in the Advisers Act and regulations thereunder.
Political Contributions. TAS Teammates who make political contributions could influence a political official’s
decision making and create a quid pro quo relationship. Contributions are defined as any gift, subscription, loan,
advance or deposit of money or anything of value made for the purpose of influencing any election for federal,
state or local office. TAS addresses these conflicts of interest by disclosing them to its Clients and by limiting the
amount a Teammate can contribute to candidates for local offices, State Political Action Committees (“PACs”),
State Parties and Bond Ballots to $250 per candidate per election, state PAC, state party or local or state bond
ballot campaign and must be eligible to vote. There is no contribution limit for candidates who currently hold a
federal office and are running for a federal office; however, a limit of $250 applies for current state or local
officeholders or officials running for a federal office per candidate per election or primary. Teammates must be
eligible to vote for such local and state candidates as well as for bod ballots. In addition, Teammates are prohibited
from holding fundraisers or otherwise soliciting contributions for a state or local candidate, national or state PAC,
national or state party or bond ballot campaigns. There is no contribution limit for candidates who currently hold
a federal office and are running for a federal office. Teammates must report contributions; however, contributions
made by Teammates to national and/or state PACs sponsored by or affiliated with Truist Financial Corporation do
not requiring reporting. TAS created these requirements for conformity with TAS’ fiduciary duties to Clients as
codified in the Advisers Act and regulations thereunder.
Premier Banker and Other Licensed Bank Employee Referrals. Advisory and securities registered Truist Bank
Premier Bankers and other advisory and securities registered bank employees are compensated on a contingent
basis for referrals of potential Clients to TAS and TAS Advisors for investment products and investment services,
including the AMC Programs. Contingent compensation for registered bank employees making referrals to TAS
gives rise to conflicts of interest because the referring licensed bank employee has a financial incentive to
introduce new investment advisory Clients to TAS and in the referred potential Client’s selection and enrollment
in an AMC Program account. TAS addresses this conflict of interest by disclosing it to its Clients and by requiring
(i) that registered bank employees referring customers to TAS or a TAS Advisor must be supervised by a TIS
registered principal and (ii) that TAS Advisors’ supervisors, or designees, must review each AMC Program account
at account-opening to determine that opening an AMC Program account is in the best interest of each Client and
their unique investment objectives and financial circumstances in conformity with TAS’ fiduciary duties to Clients
as codified in the Advisers Act and regulations thereunder.
Research Reports Created by IAG Not Used by Certain TAS Advisors. Research reports are created by IAG.
However, Advisors are not required to follow the IAG research lists. Advisors are authorized to purchase securities
that are not on the Research List. TAS addresses this conflict of interest by disclosing it to its Clients and by
requiring TAS Supervisors, or designees, to monitor accounts via certain alerts and oversight in the Envestnet
platform.
Research Reports Created by IAG and Usage of Reports by TAS IAG and Affiliated Firms. Research reports are
created by IAG and used by TAS for managing TAS managed AMC Program Client accounts is also shared with
TAS Advisors, TB and TIS. Changes to applicable TAS’ IAG research and advice are published by TAS IAG to
TAS and all TAS Advisors, TB and TIS simultaneously or as closely in time as possible. Each firm (or TAS Advisor)
is responsible for implementing the updates in accordance with their internal systems and procedures. In addition,
TB, TIS and TAS Advisors individually managing AMC Advise Program accounts and making recommendations
to AMC Allocation Plus Program accounts do not necessarily receive or act upon such research at the same time
as TAS personnel responsible for the management of the TAS managed AMC Program accounts, resulting in the
possible differing of trade execution times and prices and therefore performance due to market conditions at the
time of order execution. TAS addresses this conflict of interest by disclosing it to its Clients and by simultaneously
sharing changes to TAS’ IAG model portfolios, other investment models and investment research among TAS,
TB, TIS and TAS Advisors in conformity with TAS’ fiduciary duties to Clients as codified in the Advisers Act and
regulations thereunder. Each of TAS, Advisors servicing the TAS Advisor Managed Programs, TB and TIS
independently administer their respective investment management and advisory programs and are permitted to
use TAS’ IAG model portfolios, other investment models and investment research in different ways.
Research Reports Created by TSI and Usage of Reports by TAS. Research reports are created by TSI and can
be used by TAS Advisors for managing TAS managed AMC Program Client accounts. TAS Advisors individually
managing AMC Advise Program accounts and making recommendations to AMC Allocation Plus Program
accounts do not necessarily receive or act upon such research at the same time, resulting in the possible differing
of trade execution times and prices and therefore performance due to market conditions at the time of order
execution. TAS addresses this conflict of interest by disclosing it to its Clients in conformity with TAS’ fiduciary
duties to Clients as codified in the Advisers Act and regulations thereunder. TAS Advisors servicing the TAS
Advisor Managed Programs independently administer their respective investment management and advisory
programs and are permitted to use TSI’s equity research in different ways.
TFC Services Provided to Other Clients: Services Provided to Issuers of Recommended Securities and other
Investment Products. TFC and its affiliates provide a variety of services (including research, brokerage, asset
management, trading, lending and commercial and investment banking services) for other Clients, including
issuers of securities and sponsors of other investment products that can be recommended for purchase or sale in
AMC Program accounts or are otherwise held in AMC Program accounts. TAS believes that the nature and range
of Clients to which TFC affiliate services are rendered is such that it would be inadvisable to categorically prohibit
the use of all such securities and investment products in AMC Program accounts. Accordingly, it is likely that
securities in an AMC Program account will include some of the securities of companies for which TFC and its
affiliates perform investment banking, commercial banking or other services and investment products provided by
such companies. TAS addresses this conflict of interest by disclosing it to its Clients, disregarding any commercial
relationship TFC shall have with an issuer or product sponsor in connection with its investment research and
investment management service provided to AMC Program accounts and otherwise conducting its investment
advisory activities in conformity with TAS’ fiduciary duties to Clients as codified in the Advisers Act and regulations
thereunder.
TFC - Sterling Capital Management LLC Referral Agreement
Under the terms of TFC’s agreements with Guardian Capital Group Limited (“Guardian”) relating to TFC’s sale of
Sterling to Guardian, TFC may receive additional financial benefits if Sterling’s investment advisory, separate
account management, unified managed account model portfolio services, and other advisory services are used
in connection with TAS Program Accounts (other than Retirement Accounts). Except in the case of Retirement
Accounts, the receipt of these financial benefits by TFC creates a conflict of interest in connection with TAS’s
recommending or utilizing Sterling Advisory Services in connection with the management of its client Accounts.
TAS addresses this conflict of interest by disclosing it to its clients and mitigates this conflict of interest by
evaluating Sterling Advisory Services in its due diligence and research processes in the same manner as all
similar investment model providers and investment managers.
TAS Chief Investment Officer and Other TAS Personnel. The TAS Chief Investment Officer (“CIO”) is responsible
for and supervises IAG and is also the Chief Investment Officer and member of the board of an affiliated investment
adviser, GFO Advisory Services, LLC (“GFO”) as well as serving as Chief Investment Officer of Truist Bank’s,
Private Wealth Management segment. IAG provides significant investment services to TAS and TB; however, the
services provided to GFO are substantially different than those provided to either TAS or TB; GFO provides
Portfolio Management to GFO’s Private Funds. TAS addresses this conflict of interest by disclosing it to its Clients
and by simultaneously sharing changes to its research, models and other investment research among all its
affiliates (including TAS Advisors) in conformity with TAS’ fiduciary duties to Clients as codified in the Advisers Act
and regulations thereunder.
In relationship to services provided to GFO by other TAS IAG personnel, typically investment analysts who prepare
reports for the GFO Oversight Committee (“Committee”) and serve as voting members of the Committee related
to manager sourcing, due diligence, research of Third Party Managers and other assignments as needed for the
GFO private funds.
Additionally, certain senior management personnel of TAS serve in senior management and/or board membership
of GFO and/or TAS.
TIS Clearing Broker Credits. TAS has conflict of interests related to compensation received by TIS from NFS, TIS’
clearing firm, for the following brokerage services:
• Margin Balances– NFS credits TIS 100% of the Client margin interest income in excess of the Broker’s
Call Rate; and
• Credit Interest Cash Balances– NFS credits TIS with 80% of the credit interest on cash balances (less
any amounts credited by NFS to Client accounts) related to those accounts in which the Client has not
selected a sweep feature offered under the TIS Sweep Program.
TAS addresses this conflict of interest by disclosing it to its Clients and supervising the activities and
recommendations made by its Advisors for conformity with TAS’ fiduciary duties to Clients as codified in the
Advisers Act and regulations thereunder.
Tools and Software Available via NFS. TAS, its Advisors and affiliated broker-dealer, TIS have access to tools and
software made available by TIS’ clearing firm, NFS, at costs that are often lower than TAS, its Advisors or affiliates
could purchase directly with the providers of the tools and services.
Trade Rotation.
AMC Program Accounts
The Platform Manager, Envestnet, has a trade rotation policy; however, some investment managers on the
platform are not able to include AMC Program accounts in their standard trade rotation processes. Envestnet
monitors the performance dispersions of these investment managers, please refer to each investment manager’s
Form ADV Part 2A brochure for more information on trade rotation practices.
For Advisor managed AMC Programs, where the Advisor enters the trades in the firm’s trading system, separately
from the Envestnet platform, the system enters trades in account number sequence.
The AMC Truist Invest Program does not follow a trade rotation policy and instead places trading orders as
directed by the Algorithm.
Trading for Own and Other Accounts. TAS, TAS Advisors, model providers, investment managers and their
affiliates providing services to AMC Program accounts also develop analyses and/or evaluations of securities and
other investment products made available to AMC Program accounts, as well as buy and sell securities and other
investment products on behalf of their personal, proprietary or other Client accounts. These analyses, evaluations
and purchase and sale activities are proprietary and confidential and TAS will not disclose them to Clients. TAS
is not always able to act, in respect of Clients’ account, on any such information, analyses or evaluations which
shall come into its possession. TAS, managers and their affiliates are not obligated to affect any transaction that
they believe would violate federal or state law, or the regulations of any regulatory or self-regulatory body. TAS
addresses this conflict of interest by disclosing it to its Clients and conducting its investment advisory activities in
conformity with TAS’ fiduciary duties to Clients as codified in the Advisers Act and regulations thereunder.
Training and Educational Financial Support. TAS has conflicts of interests related to the financial support (Training
and Educational Financial Support) received by its affiliated broker-dealer, TIS in connection with products which
are also offered to TAS Program Accounts. Both TAS and TIS use the funds received from sponsors to support
investment advisor and investment representative education programs such as training seminars offered to
Advisors, branch office managers and other personnel. The receipt of these funds could potentially encouraging
TAS and/or TAS Advisors to promote and recommend products from those participating sponsors and certain
participating sponsors who contribute more financial support.
Not all sponsors of investment products offered to AMC Program accounts contribute to the education efforts.
Neither contribution towards these training and educational expenses, nor lack thereof, is considered as a factor
in analyzing or determining whether a sponsor or product should be or should remain available to AMC Program
accounts. TAS Advisors do not receive a portion of these contributions. However, their attendance and
participation in these events, as well as the increased exposure to investment products provided by participating
by sponsors, increases the likelihood that TAS advisors will recommend the products and services of those
sponsors as compared to those product providers who do not. Additional information can be found on the TAS
webpage located at https://www.truist.com/wealth/tas-disclosure.
In addition to the Training and Educational Financial Support to training and education described above, in the
ordinary course of business, TAS and its Advisors receive non-cash compensation from sponsors that includes
promotional items, occasional gifts, meals, tickets and other entertainment, sponsorship support of training events
and seminars. Clients with further questions regarding marketing support provided to TIS or TAS should contact
their TAS Advisor for additional information.
Training and Educational Financial Support contributions from participating sponsors are received and retained
by TIS. Training and Educational Financial Support and other support contributions are paid by each sponsor and
are not an additional charge to AMC Program accounts.
To mitigate this conflict, TAS Advisors do not receive additional compensation as a result of indirect compensation
received by TIS and TIS does not provide additional compensation to TAS Advisors in connection with sales of
products offered by product sponsors. In addition, TAS and TAS’ IAG do not consider Training and Educational
Financial Support participation in connection with the selection and evaluation of investments and investment
services offered to AMC Program Accounts. Instead, TAS and TAS’ IAG manage this conflict of interest by
disclosing it to its Clients and conducting its investment advisory activities in conformity with TAS’ fiduciary duties
to Clients as codified in the Advisers Act and regulations thereunder.
Truist Financial Corporation Securities. TAS has identified securities issued by Truist Financial Corporation as
presenting conflicts of interest. TAS addresses this conflict of interest by disclosing it to its Clients and by
prohibiting purchases of such securities and requiring supervisors, or designees, to move any positions received
in kind into a managed account to an unsupervised status if they remain for more than 30 days.
Truist Investment Services, Inc. Sweep Program. TAS has conflicts of interests in selecting, recommending or
defaulting to the Truist Investment Services, Inc. Sweep Program (the “Sweep Program”) as a core account sweep
service made available to AMC Program accounts because the Sweep Program provides significant financial
benefits to TAS’s affiliates, TIS and Truist Bank. The Sweep Program provides substantial deposits (including
Reciprocal Deposits) to Truist Bank at interest rates that are less than other alternative funding sources available
to it. Deposits in Sweep Program at Truist Bank also provide a stable source of funds for Truist Bank. Truist Bank
intends to use these funds to support a variety of activities, including, but not limited to, its lending activities,
investments, and other business activities, if any. The participation of Truist Bank in the Sweep Program is
expected to increase its deposits and, accordingly, overall profits. TIS also benefits from the Sweep Program
because TIS receives and retains an annual fee of up to $100 from Truist Bank on a per-account basis in
connection with AMC Program accounts enrolled in the Sweep Program’s bank deposit sweep features. In
addition, in the case of multibank Sweep Program features, TIS will receive and retain fee income in connection
with the placement of multibank deposits at Program Bank(s). The fees received by TIS in connection with
multibank sweep features can vary from Program Bank to Program Bank. The amount of fees received by TIS
from Program Bank(s) will inversely affect the interest rate paid by the Program Bank(s) on Sweep Program
balances. TAS addresses this conflict of interest by disclosing it to its Clients and by mandating that AMC Program
accounts are permitted to utilize only level rate sweep deposit features made available under the Sweep Program.
TAS also monitors the interest rate paid on the Sweep Program’s level rate features and will continue to utilize the
Sweep Program for idle cash balances only when TAS determines that based upon yield, FDIC insurance
protection availability and other investment characteristics, use of the Sweep Program’s level rate sweep deposit
features is appropriate and in accordance with TAS’ fiduciary duties to Clients as codified in the Advisers Act,
regulations thereunder. Client’s seeking additional information and disclosures regarding the Sweep Program
should contact their TAS Advisor and such materials are also available at https://www.truist.com/wealth/tis-
disclosure. Please also see Section All Programs - Core Account, below.
Use of Affiliated Broker Dealer. Unless otherwise expressly permitted by the terms of the applicable AMC Program,
investment in any of the AMC Programs requires that each Client separately maintain or open an underlying
brokerage account with TAS’s affiliated broker-dealer, TIS. The required use of an affiliated brokerage account
creates conflicts of interest on behalf of TAS in the offering and management of the AMC Programs because this
requirement provides additional revenue to TIS and, through management efficiencies, provide benefits to TAS in
reducing the cost of administering the AMC Programs. TAS addresses this conflict of interest by disclosing it to its
Clients and monitoring TIS for best execution practices through its Policy Committee for conformity with TAS
fiduciary duties to Clients as codified in the Advisers Act and regulations thereunder. TAS’ affiliate TIS receives
financial benefits in connection with TAS Client accounts held in TIS brokerage Accounts. See “TIS Clearing
Broker Credits” and “Truist Investment Services, Inc. Sweep Program” above.
ADVISORY SERVICES
All AMC Programs
In offering each AMC Program, TAS Advisors work with individual Clients to develop a personal Client profile that
identifies the Client's goals, risk tolerance, time horizon, financial situation, reasonable investment restrictions and
other factors that influence investment approach. The TAS Advisor produces an investment proposal for the Client.
The investment proposal includes an asset allocation strategy based on the Client's responses to the questions
posed by his or her TAS Advisor in the Client profile or questionnaire and/or investment vehicles. The Client then
selects the appropriate AMC Program based on this recommendation.
Initial Program Assets
Liquidation of a Client’s existing investment positions will, in the case of taxable AMC Accounts, result in the
realization of taxable income in the case of appreciated investments and losses in the case of depreciated
investments. Accordingly, Client should consult with Client’s own tax advisers prior to funding an AMC Account
with existing investment positions. TAS and any Investment Manager shall not be liable for any taxes or other
expenses incurred in connection with the sale of any existing investment position contributed in kind to an AMC
Account.
The Advisor is responsible for providing ongoing advisory services to the Client, including Client review meetings.
If for any reason, and in the sole discretion of TAS, the TAS Advisor is unable to render such investment services
to the account, temporarily or permanently, or terminates his or her employment with TAS, TAS will continue to
render such services and will assign a new TAS Advisor to the account, except that where the Client is in the AMC
Advise Program, TAS, in its sole discretion and upon notice to the Client, may instead covert the Client’s Program
to AMC Allocation Plus.
Each Client, subject to Program restrictions, is permitted to place reasonable restrictions on the management of
the account by designating specific securities or categories of securities that will not be purchased for the account.
If a Client restricts a general category of securities but does not prohibit the purchase of specific securities, TAS
will determine what specific securities fall within that category based on our determination of the primary business
of the issuer. TAS or the TAS Advisor managing the AMC Program account will make such determinations and
will allocate the assets that would have been invested in the security impacted by the restriction in one of the
following ways:
• Pro-rata across the other investments held in the portfolio; or
• To one or more substitute securities, including exchange traded funds (“ETFs”).
It is the Clients’ responsibility to inform TAS of any changes in their financial circumstances or if they wish to
change, or impose new, instructions for the management of their accounts. TAS will cause TIS to notify each Client
in writing quarterly, requesting the Client to contact his or her Advisor regarding any such changes.
Clients who invest in options in applicable AMC Programs should read and fully understand the margin disclosure
in the Fees Section above as well as the OCC publication “Characteristics and Risks of Standardized Options”, a
copy of which will be provided to Client before election of option capabilities. Short Selling is prohibited and,
except as otherwise expressly provided by the terms of an AMC Program, the use of margin is also prohibited.
Clients can provide verbal approvals for certain changes made to their AMC Program accounts, such as changing
Programs or Third Party Managers, investment models, asset allocations percentages, applicable eligible
investment elections and/or investment risk levels, fee modifications, rebalancing option frequency, add or remove
overlay services and/or termination of an AMC Program investment advisory relationship. AMC Program Clients
will receive notification related to the changes described above in addition to any additional required
documentation such as a copy of the Statement of Investment Selection and the new Manager’s brochure, privacy
policy and Form CRS for Third Party Manager change. NOTE: AMC Program Account changes related to fee
increases, Client Restrictions and/or Client e-delivery acceptance will require Client’s physical signature
or approved e-signature of required account documentation materials.
Clients retain complete ownership of all cash, securities, and other investments in their AMC Program accounts.
In AMC Annuity Program accounts, Clients retain a direct contract with the applicable insurance company.
Clients have the option to purchase investment products that TAS recommends to AMC Program accounts through
other broker-dealers or agents that are not affiliated with TAS.
There is no guarantee that a Client’s investment objectives in an AMC Program will be achieved, and past
performance is not a guarantee of future results.
Termination of AMC Program Relationship
Upon termination of an AMC Program relationship, with the exception of an AMC Annuity Program relationship,
Client’s AMC Program account will revert to an unmanaged full service TIS brokerage account. The timing of an
AMC Program account’s termination can take several days and more time is generally required if the account is
also managed by a Third Party Manager and/or the platform manager.
Reasons for termination the AMC Annuity relationship include but aren’t limited to the following:
• No funds available to cover the quarterly Program Fee;
• TAS Advisor failure to provide investment management services or Client refusal to follow STAS
recommendations; and/or
• Client requests to end the AMC Annuity Program advisory relationship.
Upon termination of the AMC Annuity Program relationship three options are available to Program Client, the
annuity account:
•
With the consent of TAS, the account can remain with the Client’s TAS Advisor and no quarterly
advisory fee is charged;
•
With the consent of TAS, the account can be transferred to the TAS Client Advisor Center and no
quarterly advisory fee will be charged; and/or
•
The account can be transferred by the Client to the insurance company to
o
Become a house account maintained directly with the applicable annuity carrier; and/or
o
The account can be transferred by Client to another financial institution selected by Client.
Account Transfer to Another Firm
When Client elects to transfer their AMC Program account to another firm through an ACAT process, the
investment advisory relationship with TAS will terminate. Any fees, commissions or other charges related to the
liquidation of the AMC Program account assets will be charged to the account prior to transfer.
Class Action Suits
As custodian, NFS researches Client ownership of certified class action suits involving securities for which it holds
custody. After a class action suit has been certified, NFS will screen Client ownership records using the specific
criteria defined in the suit. Client names and addresses meeting the specified criteria will be provided to the claims
administrator assigned by the courts. The claims administrator will then mail all class action notices to the Client.
Client may elect to participate in the suit; however, TAS and NFS are not responsible for submitting documents of
behalf of Client.
Core Account – TIS Sweep Program
Client’s brokerage account contains a “core account” used for settling transactions and holding credit balances.
All cash proceeds from sell transactions and other credit balances will be retained in the core account. Funds
held in each AMC Program account’s core account are part of the applicable AMC Program and as such are
subject to the applicable Program Fee.
TAS has selected the Truist Investment Services, Inc. Sweep Program’s TIS Level Rate Multibank Sweep Feature
(taxable accounts) and TIS Level Rate Single Bank Sweep feature (IRA, Qualified Plan and SEP & SIMPLE IRA
accounts) as the cash sweep investment vehicle for the core account of each AMC Program Client’s brokerage
account which is used for settling transactions and holding credit balances. Taxable AMC Program Client accounts
are enrolled in the TIS Sweep Program’s TIS Level Rate Multibank sweep feature and will have their idle cash
balances automatically swept into an interest-bearing deposit account(s) at Truist Bank, a federally insured
banking institution, and other Program Bank(s) which are also federally insured banking institutions. Cash
balances deposited in the TIS Level Rate Multibank sweep feature. will be eligible for FDIC insurance coverage
up to $2,465,000 (principal plus accrued interest) per depositor per insurance capacity, in accordance with
applicable FDIC rules. IRA, Qualified Plan and SEP & SIMPLE IRA AMC Program Client Accounts are enrolled in
the TIS Sweep Program ‘s Truist Bank Level Rate Single Bank sweep feature and will have cash balances in their
AMC Program accounts automatically swept into an interest-bearing deposit account at Truist Bank, a federally
insured banking institution. Cash balances deposited in the Truist Bank Level Rate Single Bank sweep feature will
be eligible for FDIC insurance coverage up to $250,000 (principal plus accrued interest) per depositor per
insurance capacity, in accordance with applicable FDIC rules.
The terms of the TIS Sweep Program and account eligibility for sweep features available under the Sweep
Program are more fully described in the TIS Sweep Program Disclosure Statement (“TIS Disclosure Statement”)
provided to AMC Program Clients in connection with the establishment of each Client’s associated Truist
Investment Services, Inc. brokerage account, as the same shall be revised or amended. The terms of the TIS
Disclosure Statement are incorporated herein by reference with like effect as if set forth herein verbatim. Clients
can obtain current information regarding the TIS Sweep Program and a copy of the most recent TIS Disclosure
Statement and list of participating Program Banks at any time free of charge by contacting a TAS Advisor. Except
in the case of a very limited number of account types, all sweep features offered to AMC Program Clients under
the terms of the TIS Sweep Program consist of deposit accounts with TAS’s affiliate, Trust Bank (and in the case
of multibank sweep features, other FDIC insured banks which pay fees to TIS and/or Truist Bank in connection
with the operation of the multibank sweep features.
TAS’ selection of the TIS Sweep Program as the sweep vehicle for each AMC Program Client’s brokerage account
provides significant benefits to TAS’s affiliates TIS and Truist Bank and therefore creates conflicts of interest
between TAS and connection with offering and managing the AMC Programs. Clients should consult the TIS
Disclosure Statement for additional information concerning the benefits received by TIS, TAS, TB and other
affiliates in connection with TIS Sweep Program deposits. See Conflicts of Interest – Truist Investment
Services, Inc. Sweep Program Section above.
AMC Program Clients should be aware that all deposits (for example, deposits Clients shall make at Truist
Bank or applicable Program Bank(s) (in a CD, Checking or saving account (outside of the Truist
Investment Services, Inc. Sweep Program plus the Sweep Program deposit cash balance) held by an
individual in the same right and legal capacity at the same bank are aggregated and insured up to
$250,000. Special rules apply to FDIC insurance of trust deposits. All FDIC insurance coverage is in
accordance with FDIC rules.
Neither TAS, TIS, Truist Bank nor any other Program Bank or NFS will monitor the amount of Client’s AMC
Program account TIS Sweep Program deposit balances for determining whether any Client Account
exceeds the limit of available FDIC insurance. Clients are solely responsible for monitoring the total
amount of their assets on deposit with Truist Bank and each Program Bank (including accounts at Truist
Bank and Program Bank held in the same right and legal capacity) in order to determine the extent of
deposit insurance coverage available to them on those deposits, including their Sweep Program balances
held at Truist Bank and other Program Banks. Clients who are trustees are responsible for determining
the application of FDIC insurance for themselves and their beneficiaries.
The TIS Sweep Program is not intended for long-term investments and yields can be lower than those of similar
investment vehicles or bank deposit accounts offered outside of the sweep options available on the TAS platform.
Clients who desire to maintain money market positions for other than a short-term period should contact their TAS
Advisor or contact TAS at the address or phone number on the front of this brochure to select non-Sweep Program
investments for permanent stable value investment purposes.
Tax Lot Disposal Method
All AMC Program accounts will be coded with a Tax-Sensitive disposal method. When Assets in an AMC Program
account are partially (but not fully) sold, an estimated tax liability will be used to determine the shares to be
depleted first. With the exception of the AMC Truist Invest Program, Clients may elect a different lot disposal
method. Clients should discuss the impact of the Tax Sensitive disposal method with their tax advisor.
Systematic Withdrawal Plans: The source of funding for periodic distributions in AMC Program accounts that have
a systematic withdrawal plan (“SWP”) in place is the account’s core account position. If there are insufficient funds
available in the applicable account to cover a SWP distribution, the investment manager of discretionary AMC
Program accounts will review the account and determine which securities to sell to in order to fully satisfy any
SWP distribution.
Trade Errors: When a trade error is discovered, TAS requires that the Client’s AMC Program Account is corrected
in a timely manner. Clients are made whole for losses and gains resulting from a trading error are held at TIS.
AMC Advise
The AMC Advise Program is a discretionary investment management Program offering, individualized investment
management by approved TAS Advisors for an asset-based fee. Clients do not direct investment transactions for
their accounts enrolled in this Program. Instead, the Client authorizes an approved TAS Advisor to manage the
Client’s designated assets on a discretionary basis by purchasing and/or selling individual stocks, bonds, mutual
funds, closed-end funds, exchange-traded funds, certificates of deposit, money market instruments, depository
receipts or other similar instruments relating to any of these securities within guidelines set by the TIS/TAS Policy
Committee for portfolio construction and limitation of risk. Limited types of options transactions can be conducted
for the account. Clients should read and fully understand the margin disclosure in the Fees section above as well
as the OCC publication “Characteristics and Risks of Standardized Options”, a copy of which will be provided to
Client before election of option capabilities. Investment strategies utilizing margin or short selling are prohibited.
The Advisor also provides ongoing advisory services to the Client, including Client review meetings.
The AMC Advise Program permits the TAS Advisor managing the Program account to periodically adjust or
rebalance the account’s portfolio asset allocation to be more conservative without requiring written consent by the
Client or adjustment to the account’s long-term risk target. Clients will be sent a semi-annual notice indicating the
risk target assigned to the account and the current risk target that aligns with account holdings. NOTE: As a
result of the discretion granted to the TAS Advisor managing the account, the actual risk profile of the
assets in A Client’s AMC Advise Program account may be lower than the risk level specified in the Client’s
Statement of Investment Selection.
Retirement Accounts enrolled in this Program are not permitted to invest in Affiliated Private Funds.
AMC Allocation Plus
The AMC Allocation Plus Program is a non-discretionary investment advisory Program offering, individualized
investment recommendations by TAS Advisors for an asset-based fee. Investment decisions for accounts enrolled
in this Program are those of the Client and not their TAS Advisor or TAS. The Client’s TAS Advisor will be primarily
responsible for making investment management recommendations for the AMC Allocation Plus Program account
in accordance with Client’s investment objectives as stated in the Client’s Client profile, which the Client can elect
to use to invest and reinvest the assets in securities within guidelines set by the TIS/TAS Policy Committee,
including TAS’ IAG’s Research List which includes various types of investment vehicles, such as common and
preferred stocks, bonds, mutual funds, closed-end funds, exchange traded funds, certificates of deposits, money
market instruments, alternative investments or other similar investment vehicles within guidelines set by the
TIS/TAS Policy Committee. The Advisor also provides ongoing advisory services to the Client, including Client
review meetings. Limited types of options transactions are permitted to conducted for the account. Clients should
read and fully understand the margin disclosure in the Fees section above as well as the OCC publication
“Characteristics and Risks of Standardized Options”, a copy of which will be provided to Client before election of
option capabilities. Investment strategies utilizing short selling are prohibited.
The AMC Allocation Plus Program permits the TAS Advisor managing the Program account to periodically adjust
or rebalance the account’s portfolio asset allocation to be more conservative without requiring written consent by
the Client or adjustment to the account’s long-term risk target. Clients will be sent a semi-annual notice indicating
the risk target assigned to the account and the current risk target that aligns with account holdings. NOTE: As a
result of the discretion granted to the TAS Advisor managing the account, the actual risk profile of the assets in A
Client’s AMC Allocation Plus Program account may be lower than the risk level specified in the Client’s Statement
of Investment Selection.
TAS Advisors participating in the AMC Advise and AMC Allocation Plus Programs may also use models created
by IAG to manage Client portfolios they manage either on a discretionary or non-discretionary basis. A conflict of
interest may exist when TAS Advisors use the same models that TAS IAG utilizes for managing the TAS AMC
Program portfolios. See Conflict of Interest – Models Created by IAG for Management of AMC Program
Portfolios vs TAS Advisor Usage of the Models for Client Portfolio Management section above for details.
Please see the TAS AMC Advisor Managed Programs Firm Brochure available on our website:
https://www.truist.com/wealth/tas-disclosure for details related to these programs.
AMC Allocation Plus or AMC Advise Program Clients can elect to enroll their accounts in the Brokerage Checking
Service and link their Program accounts with their Signature Advantage” checking account for Truist Bank, or
“Asset Management Account” for checking accounts. Client’s electing the Brokerage Checking Service will not
pay AMC Allocation Plus or AMC Advise Program Fees on cash balances, if any, transferred to and held in their
Truist Bank checking account. Client cash and TIS Sweep Program balances held in Client’s AMC Program
Account will be subject to and included in the calculation of the account’s AMC Program Fee. See CONFLICTS
OF INTEREST – Truist Investment Services, Inc. Sweep Deposit Option Section above.
Retirement Accounts enrolled in this Program are not permitted to invest in Affiliated Private Funds.
AMC Annuity
The AMC Annuity Program is a non-discretionary investment advisory Program offering individualized investment
recommendations by TAS Advisors for an asset-based fee. Investment decisions for accounts enrolled in this
Program are those of the Client and not their TAS Advisor or TAS. Client’s TAS Advisor will be primarily responsible
for making recommendations in accordance with Client’s investment objectives as stated in the Client’s Client
profile, which the Client can elect to use in connection with selecting an annuity product to purchase and investing
in investment options made available by the annuity provider. The TAS Advisor also provides ongoing advisory
recommendations and other services to the Client related to monitoring of the annuity’s investment sub-accounts,
including Client annual investment review meetings.
Client’s TAS Advisor will continue to act as the servicing agent on the contract and will be entitled to all rights
Client assigns to their TAS Advisor as determined in the annuity contract. As a part of the AMC Program account,
the TAS Advisor will recommend an asset allocation within each Client’s annuity contract. As contract owner,
Client will retain the ability to reallocate their annuity contract directly with the carrier. Reallocations without TAS
input or oversight will limit TAS’s ability to effectively serve as investment adviser on the Program account and
can compromise performance. If material reallocations or changes to the annuity contract are identified, the TAS
Advisor will contact Client to recommend changes that will realign the annuity with TAS’s recommendations. If
Client chooses not to accept TAS’s recommendations, TAS may terminate Client’s Program account with 30-days
written notice to Client. Subaccount transactions within Client’s annuity account can also be subject to restrictions
and/or limitations. Clients are encouraged to review the applicable annuity contract and/or product prospectus for
specific details regarding investment options offered by each annuity provider.
Upon establishing an AMC Annuity Program account, the account value will not be immediately available for
review on any TAS or TIS online account portals. If the AMC Annuity Program account is being funded from an
existing AMC Program account or TIS brokerage account, Client’s account will be debited and the funds
transferred directly to the insurance company. Account opening and processing time will vary based upon each
insurance carrier’s processes and procedures.
Annuitization
Client should consult with their tax advisor prior to annuitizing a contract as some states may impose applicable
premium taxes.
AMC Fund Select Tactical
Client Program accounts are managed in accordance with certain asset allocation and portfolio investment
models/portfolios selected by the Client in the Client’s Statement of Investment Selection. In addition to TAS
internally developed models, TAS has contracted with Third Party Model Portfolio Providers which also provide
additional models used by TAS with respect to investments in Client Program accounts.
Eligible investments in this Program are limited to mutual fund shares and ETF shares. In administering this
program TAS utilizes various mutual fund and ETF model portfolios and asset allocation models which reflect
differing risk profiles.
Model Provider Models
In addition to TAS’ Investment Advisory Group which provides model portfolio and asset allocation models, TAS
has agreements with Third Party Model Portfolio Providers which are made available to Client Program accounts
(for an additional fee). Participating Third Party Model Portfolio Providers do not receive information regarding
Client identity, circumstances, financial condition, portfolio holdings, tax situation, regulatory status or financial
needs or goals. Except for the provision of the relevant investment model(s), model providers are not responsible
for determining the appropriateness or suitability of investment model(s), or of any of the securities included from
time to time in the investment model(s) for any specific Client. TAS and the Client’s TAS Advisor are responsible
for providing investment advice to Client accounts enrolled in this Program.
When a Third Party Model Portfolio Provider makes model portfolio changes, the provider will notify TAS, or the
Platform Manager as its designee, at the same time or after the provider has effected model changes in its own
Client accounts. When TAS, or its designee, is notified of the model portfolio changes, TAS or its designee will,
in its discretion, cause corresponding changes to Program Client portfolio. TAS reserves the right to not accept a
particular Third Party Model Portfolio Provider recommendation and to cause AMC Program Client accounts to
become invested in ways which deviate from the applicable model portfolio. For example, if a recommended
security would cause the account to violate Client’s account restrictions, TAS, or its designee, will not purchase
that security for the affected Client’s account. As a result of the timing of model change notifications and TAS’, or
its designee’s, processes and procedures, Third Party Model Portfolio Providers can affect trades on behalf of
their direct Clients’ accounts before TAS, or its designee, places corresponding trades in AMC Program accounts.
Therefore, in connection with model portfolio changes, due to the potential for the markets to react to trades
executed on behalf of a model provider’s direct Clients, AMC Program Clients can, depending upon market
conditions, be at a disadvantage when compared to a Third Party Model Portfolio Provider’s hi direct Clients
respect to such trades.
When Third Party Models are selected, TAS utilizes the Third Party Model Portfolio Provider’s security selections
and does not apply its IAG research or Research List. Therefore, Program accounts using third-party models can
contain securities that are neither researched nor on any of the lists maintained by TAS’ IAG.
AMC Fund Select Tactical Focus
The AMC Fund Select Tactical Focus Program is a fully discretionary investment management Program offering
Client accounts enrolled in the Program an array of exchange traded fund portfolios or Third-Party Manager model
portfolios that are based on risk-based modeling using asset allocation for an asset-based fee. Clients do not
direct investment transactions for their accounts enrolled in this Program. Instead, Client accounts will be invested
in accordance with Client’s investment objectives as stated in the Client’s Client profile on a discretionary basis
utilizing ETF asset allocation model portfolios provided by TAS’ IAG or Third Party Managers which reflect differing
risk profiles. Third-Party Manager models may also include mutual funds, as well as other securities. TAS is
granted discretionary investment authority over account assets.
The principal differences between the Fund Select Tactical Program and the AMC Fund Select Tactical Focus
Program are that 1) the Fund Select Tactical Focus Program offers fewer available models and has a lower
minimum required funding amount than the AMC Fund Select Tactical Program.
AMC Pinnacle/AMC Pinnacle – Sleeve Select
TAS and Envestnet are co-advisers of the AMC Pinnacle and AMC Pinnacle – Sleeve Select Programs. TAS or
TAS Advisors act as investment manager for each of the Program Sleeves. Envestnet is permitted, in its sole
discretion to determine whether to accept or reject a Client or Account’s participation in the Program. The Third
Party Manager(s) selected by Clients in the SMA sleeve have sole discretion for the assets assigned to them for
management. TAS Advisors manage portfolios in the Adviser Managed Sleeves, on both a discretionary and
nondiscretionary basis.
For certain previously established AMC Pinnacle accounts, Advisors may, in the exercise of their discretion (1)
elect to allocation contributions or make withdrawals from a specific Sleeve and/or (ii) elect to allocate
contributions or make withdrawals from the entire portfolio based on the overall weights to each Sleeve.
All accounts in the AMC Pinnacle – Sleeve Select Program grant Advisors discretion to (i) elect to allocate
contributions or make withdrawals from a specific Sleeve and/or (ii) allocate contributions or make withdrawals
from the entire portfolio based on the overall weights to each Sleeve.
Sleeves
All Sleeves
Client investments within each Sleeve are managed in accordance with certain asset allocation and portfolio
investment models/portfolios selected by the Client in the Client’s Statement of Investment Selection. In addition
to TAS internally developed models, TAS has contracted with Third Party Model Portfolio Providers which provide
additional models used by TAS with respect to investments in the various Sleeves, as well as Envestnet related
to its fixed income managers for separate account management of fixed income portfolios. TAS does not charge
additional fees with respect to the use of its internally developed investment models. However, except as provided
below, if Client elects to use a Third Party Model Portfolio Provider’s model, Client’s Program account will incur
any additional increased direct costs associated with the Client’s selection of non-TAS developed models in
connection with Program investments.
TAS is the investment manager of each of the Sleeves described below:
Strategist Sleeve
The “Strategist Sleeve” consists of models provided by TAS’ Investment Advisory Group and Third Party Model
Portfolio Providers consisting of a wide range of securities, including equity, fixed income and alternatives, among
others, in order to provide Clients with the ability to utilize the portfolio management services of a select, pre-
screened group of model portfolio providers available through TAS which contracts directly with the model
providers to offer individualized investment management services to TAS Clients (for an additional fee).
In connection with this Program, Client’s grants discretionary portfolio management authority to TAS and TAS, as
investment manager exercises investment discretion with respect to the management of the Client’s investments
in the Strategist Sleeve. TAS’ investment discretion includes the selection and maintenance of model providers
and models, mutual funds and ETFs; modification of model portfolios and allocation profiles; and the addition,
replacement, reduction or elimination of any investment used in connection with the management of Client
Program accounts.
When a Third Party Model Portfolio Provider makes model portfolio changes, the provider will notify TAS, or its
designee, at the same time or after the provider has effected model changes in its own Client accounts. When
TAS, or its designee, is notified of the model portfolio changes, TAS or its designee will, in its discretion, cause
corresponding changes to Program Clients’ portfolios. TAS reserves the right to not accept a particular Third Party
Model Portfolio Provider recommendation and to cause AMC Program Client accounts to become invested in
ways which deviate from the applicable model portfolio. For example, if a recommended security would cause
the account to violate Client’s account restrictions, TAS, or its designee, will not purchase that security for the
affected Client’s account. As a result of the timing of model change notifications and TAS’, or its designee’s,
processes and procedures, Third Party Model Portfolio Providers can affect trades on behalf of their direct Clients’
accounts before TAS, or its designee, places corresponding trades in AMC Program accounts. Therefore, in
connection with model portfolio changes, due to the potential for the markets to react to trades executed on behalf
of a model provider’s direct Clients, AMC Program Clients can, depending upon market conditions, be at a
disadvantage when compared to Third Party Model Portfolio Provider’s direct Client’s respect to such trades.
Where Third Party Models are selected, TAS utilizes the model provider’s security selections and does not apply
its IAG research or Research Lists. Therefore, Client Program accounts can contain securities that are neither
researched nor on any of the aforesaid lists maintained by TAS IAG.
TAS retains the authority to terminate or change models within the MM Sleeve without prior notice to the affected
Clients when extenuating circumstances are such that TAS believes such termination or change is in the best
interest of the Client. In such cases, an alternate model will be selected, and Client will be notified in writing of the
change and affected investments funds will be reallocated among other selected models. Should a Client reject
an alternative model selected by TAS, the assets in the terminated model sleeve will be reallocated across the
remaining sleeves by Envestnet as Overlay Manager. If there are no other sleeves, the account will be reclassified
as a full service TIS brokerage account.
Advisor Managed Sleeves
TAS Advisors manage the “Advisor Sleeves” which consist of the Advisor Managed Discretionary Sleeve and
Advisor Supported Non-Discretionary Sleeve. Investments must trade on an exchange to be in the sleeves.
Advisor Managed Discretionary Sleeve
The “Advisor Managed Discretionary Sleeve” provides discretionary, individualized investment management of
the Sleeve’s investments by certain approved TAS Advisors. Clients generally do not direct transactions for
investments allocated to this Sleeve. Instead, the Client authorizes a TAS Advisor to manage the Client’s
designated assets allocated to this Sleeve on a fully discretionary basis for the purchase and sale of exchange-
traded securities, within guidelines set by the TIS/TAS Policy Committee for portfolio construction and limitation
of risk. Limited types of options transactions within guidelines set by the TIS/TAS Policy Committee are permitted
to be used as part of investments managed within this Sleeve of the Program; however, investment strategies
utilizing margin or short selling are prohibited.
Clients electing to use options as part of this Program will need to contact their TAS Advisor when transactions in
underlying securities are needed for cash flow or other reasons. Clients must indicate preferred maximum account
loss they are willing to accept with respect to options transactions; however, there are no guarantees that losses
will be limited. Clients must also enter into a margin agreement and an options agreement. Both TIS and NFS
must approve these agreements prior to the implementation of a concentrated stock overlay management in an
account. Clients will be provided with additional margin and options disclosures which they should read carefully.
Clients who invest in options in applicable AMC Programs should also read and fully understand the margin
disclosure in the Fees Section above as well as the OCC publication “Characteristics and Risks of Standardized
Options”, a copy of which will be provided to Client before election of option capabilities.
Advisor Non - Discretionary Sleeve
The “Advisor Non-Discretionary Sleeve” provides non-discretionary, individualized investment management of the
Sleeve’s investments. Advisors participating in this Sleeve of the Program do not have to be pre-approved by TAS
as is the case in the Advisor Discretionary Sleeve. The TAS Advisor is primarily responsible for making investment
management recommendations. The initial and all subsequent investment decisions including selection of
applicable models and following, or disregarding, changes suggested by applicable models are made by the Client
and not by their TAS Advisor or TAS. After the initial model is established for an Account, rebalancing is conducted
on a discretionary basis by Envestnet as overlay manager.
In accordance with Client’s investment objectives as stated in the Client’s investment profile, within this sleeve the
TAS Advisor can recommend that a Client invest and reinvest the assets in securities on the firm’s IAG Research
List which includes various types of securities, including, but not limited to, common and preferred stocks, shares
of mutual funds, closed-end funds, and exchange-traded funds and alternative investments within guidelines set
by the TIS/TAS Policy Committee.
TAS Advisors who manage sleeves of AMC Pinnacle or AMC Pinnacle – Sleeve Select Program portfolios can
also manage Client AMC Allocation Plus and/or AMC Advise Program portfolios and when they do, trades effected
in the AMC Pinnacle and/or AMC Pinnacle – Sleeve Select Advisor managed Sleeves are entered by Envestnet,
who has overlay responsibilities related to all the trades in the AMC Pinnacle and/or AMC Pinnacle – Sleeve
Select program; however, similar trades in AMC Allocation Plus or AMC Advise portfolios are sent directly to NFS,
the clearing firm for TIS. This difference can result in similar trades executing at different times and at different
prices for the same security. Generally, those trades in the AMC Allocation Plus and AMC Advise portfolios are
executed before those in the AMC Pinnacle and/or AMC Pinnacle – Sleeve Select Advisor managed sleeve.
Fixed Income Manager Sleeve
The Fixed Income Manager Sleeve provides Clients’ access to AMC Premier and Envestnet’s fixed income
investment managers available in the Sentry program. These services include:
• Providing access to Fixed Income SMA investment managers (“Envestnet Managers”). The Envestnet
Managers have entered into sub-management agreements with Envestnet to provide discretionary
account management services;
• Providing administrative and /or trading services as directed by an Envestnet Manager;
• Rebalancing services to maintain an account’s asset allocation; and
• Acting on any reasonable restrictions that Client imposes on the management of an account including
designation of particular securities or types of securities that Client does not want purchased.
TAS will recommend an appropriate asset allocation among the Envestnet Managers in the Envestnet Sentry
program and recommend Envestnet Manager(s) for Client’s Program accounts. In recommending Envestnet
Managers for the Program accounts, TAS will consider factors it deems relevant, including but not limited to, the
investment goals and objectives of Client, and any reasonable restrictions imposed by Client on management of
the Accounts including the designation of particular securities or types of securities that should not be purchased
for the Accounts, or that should be sold if held in the Accounts.
TAS relies upon Envestnet for analysis and information and the identification, selection and monitoring of the
various Fixed Income Envestnet Managers offered. Envestnet has conducted due diligence on Envestnet
Managers considered “Approved”. Only “Approved” Managers are available for the Fixed Income Sleeve. If
Envestnet removes a Manager from the “Approved” status, in such cases, an alternate Manager will be selected
and the Client will be notified in writing of the change and affected investments funds will be reallocated among
other selected Managers. Should a Client reject an alternative Manager selected by TAS, the assets in the
terminated Manager sleeve will be reallocated across the remaining sleeves by Envestnet as overlay manager. If
there are no other sleeves, the account will revert to a regular TIS brokerage account.
TAS Advisors can utilize this information in addition to other research related to Client recommendations, if
applicable or when conducting its review of Envestnet Managers and Envestnet.
See FEES Section above regarding how the Program Fee is calculated for the AMC Pinnacle Program when more
than one Sleeve is selected.
Clients electing this Program should carefully review the applicable Envestnet’s Form ADV, Part 2A for more
information about its services.
AMC Premier Program
In connection with offering this Program TAS contracts with the Third Party Model Portfolio Providers and Third
Party Managers and may terminate or change Third Party Model Portfolio Providers and Third Party Managers
when it deems necessary. In those instances, where TAS utilizes Third Party Managers who have contracted
directly with Envestnet, Envestnet, not TAS, may terminate or change Third Party Investment Managers when it
deems necessary.
TAS is also investment manager of Program accounts which are managed in accordance with investment models
that TAS Advisors recommend. TAS Advisors also recommend investment managers to Clients enrolled in this
Program and manage the Client relationship.
Third Party Models
TAS has agreements with Third Party Model Portfolio Providers which provide additional model portfolios which
TAS (for an additional fee) is authorized to utilize in connection with the management of Client accounts invested
in this Program. Third Party Model Portfolio Providers do not receive information regarding Client identity,
circumstances, financial condition, portfolio holdings, tax situation, regulatory status or financial needs or goals.
Except for the provision of the relevant investment model(s), a Third Party Model Portfolio Provider has no
obligation for the provision of specific advice to a Program Client. Third-party model providers are not responsible
for determining the appropriateness or suitability of investment model(s), or of any of the securities included from
time to time in the investment model(s) for any specific Client.
When a Third Party Model Portfolio Provider makes model portfolio changes, the provider will notify TAS, or its
designee, at the same time or after the provider has effected model changes in its own Client accounts. When
TAS, or its designee, is notified of the model portfolio changes, TAS or its designee will, in its discretion, cause
corresponding changes to Program Clients’ portfolios. TAS reserves the right to not accept a particular Third Party
Model Portfolio Provider’s recommendation and to cause AMC Program Client accounts to become invested in
ways which deviate from the applicable model portfolio. For example, if a recommended security would cause
the account to violate Client’s account restrictions, TAS, or its designee, will not purchase that security for the
affected Client’s account. As a result of the timing of model change notifications and TAS’, or its designee’s,
processes and procedures Third Party Model Portfolio Providers can make trades on behalf of their direct Clients’
accounts before TAS, or its designee, places corresponding trades in AMC Program accounts. Therefore, in
connection with model portfolio changes, due to the potential for the markets to react to trades executed on behalf
of a model provider’s direct Clients, AMC Program Clients can, depending upon market conditions, be at a
disadvantage when compared to Third Party Model Portfolio Provider’s direct Client’s respect to such trades.
TAS’ recommendation of TAS or Sterling as a model portfolio provider creates conflicts of interest in connection
with TAS’ offering and administration of this Program. See Sections Conflicts of Interest –TAS as Model
Provider; TFC - Sterling Capital Management LLC Referral Agreement above for more specific information.
As the investment manager of the model portfolios, TAS has investment discretion with respect to managing the
Client’s investments. TAS’ discretion includes the selection and maintenance of model providers and models,
individual securities; modification to investment models and allocation profiles; and the addition, replacement,
reduction or elimination of any investment held in Client accounts.
Where Third Party Models are selected, TAS utilizes the Third Party Model Portfolio Provider’s security selections.
Therefore, Client Program accounts can contain securities that are not researched by TAS IAG.
TAS retains the authority to terminate or change applicable investment models without prior notice to affected
Clients when extenuating circumstances are such that TAS believes such termination or change is in the Clients’
best interest. In such cases, an alternate model will be selected, Clients will be notified in writing of the change
of the applicable model and affected investments funds will be reallocated among other selected models.
Third-Party I Manager Accounts
TAS Advisors recommend TAS and/or Third Party Managers, including Sterling, to Clients. Investment managers
approved by Clients, manage Client portfolios on a discretionary basis. TAS Advisors also manage the Client
relationship.
TAS retains the authority to terminate or Third Party Managers when extenuating circumstances are such that
TAS believes such termination or change is in the best interest of the Client. In such cases, an alternate
investment manager will be selected, and the Client will be notified in writing of the change of investment manager.
Should Client wish to retain any terminated investment manager, Client will be required to establish a separate
investment management relationship with the new Third Party Manager.
TAS’ recommendation of Sterling as an investment manager creates conflicts of interest in connection with TAS’
offering and administration of this Program. See Section Conflicts of Interest – TFC - Sterling Capital
Management LLC Referral Agreement above for more specific information.
AMC Fund Select Tactical and AMC Premier – Fidelity Investments® Charitable Gift Fund
TAS Advisors are prohibited from being an Account Holder with respect to any assets invested in the Fidelity
Investments Charitable Gift Fund including accounts of family members or related entities.
Giving Accounts are subject to each AMC Program’s minimum funding amount. Giving Accounts that fall below a
Program’s minimum funding amount may be invested by Fidelity Charitable in other investment pools.
Fidelity Charitable charges additional administrative fees on Giving Accounts. See section Fees, Fidelity
Investments® Charitable Gift Fund, above.
Envestnet Sentry Program
TAS has contracted with Envestnet who has contracts with the Envestnet Managers in the Envestnet Sentry
Program and may terminate or change Managers when necessary. TAS and Envestnet serve as co-advisers and
must approve Client’s participation in the Program. TAS Advisors recommend Envestnet Managers to Clients and
manage the Client relationship.
TAS relies primarily upon Envestnet for analysis and information and the identification, selection and monitoring
of the various Envestnet Managers offered through the program; however, TAS’ IAG does perform similar
processes related to some Managers in the program. Envestnet has conducted due diligence on Envestnet
Managers considered “Approved”. Those Envestnet Managers in which Envestnet does not conduct due diligence,
or Approved Envestnet Managers which do meet performance standards established by Envestnet, are
considered “Available”. Envestnet in its sole discretion determines if an Envestnet Manager will be considered
“Approved” or “Available”.
TAS Advisors can utilize this information in addition to other research related to Client recommendations, if
applicable and available through the exception process.
TAS can also utilize this information in addition to other due diligence when conducting its review of Model
Providers and Envestnet.
If an Envestnet Manager is removed from the platform, Client and their TAS Advisor will receive notice to change
to a new investment manager. If no change is made, the program account will be reclassified as a standard
commission brokerage account.
TAS’ Investment Consulting Group conducts due diligence on Envestnet as a sub-advisor. The review is based
on applicable information gathered from various sources, including information from Envestnet, disclosure
documents and personnel changes among other items.
Participation in the Envestnet Sentry Program is subject to approval by Envestnet. Envestnet in its sole discretion
can determine whether to accept or reject a Client or Account’s participation in the Envestnet Sentry Program.
Upon opening a Envestnet Sentry Account Client will become an investment management Client of TAS,
Envestnet and the respective Envestnet Manager(s).
Clients electing this program should carefully review Envestnet’s Form ADV, Part 2A for more information about
its services.
Overlay Services by Platform Manager
Tax Overlay Services
When a Manager makes a change to its model, the Platform Manager:
• Weighs the impact of transactions on taxes against the risk of not complying with the Manager’s
changes;
• Maintains responsibility for the account administration and coordinates all trades; and,
• Can elect to prevent the transaction or look to make additional changes to balance the change, if the
individual Client’s tax situation dictates that the transaction shall not occur.
As is the case with all tax-managed accounts, there is a trade-off between realizing gains and adhering to the
Manager’s model. Differences between how tax-managed accounts are managed and the Manager’s models is
measured by tracking error (“TE”). The Platform Manager seeks to limit the amount of TE while balancing the tax
implications of each transaction within a Client’s account and replicate the Manager’s model as closely as
possible, subject to the Client’s specific tax situation.
Tax Overlay Services are not available for most Client assets held away from TIS and NFS.
Impact Overlay Services
The Platform Manager provides the Impact Overlay Service which allows Clients to integrate environmental, social
and governance factors into their investments based on their own personal values while staying as consistent as
possible with the risk/return characteristics provided by the model portfolio.
Impact Overlay Services are not available for most Client assets held away from TIS and NFS.
After reviewing and approving the investment proposal, the Client, with the Advisor's assistance, opens an AMC
Program account and signs an investment advisory agreement authorizing management of the account in
accordance with the terms and conditions of the AMC Program selected.
The Platform Manager provides TAS with a quarterly investment performance report (“Quarterly Report”) for each
Client. This is a detailed report on the Client's assets invested in the Program, including performance data for the
most recent quarter, year-to-date and since-inception-to-date. The Quarterly Report includes:
• Market Commentary
• Current Account Holdings
• Account Performance
• Transaction Detail
TAS believes this information is reliable; however, TAS does not independently verify the accuracy of any
information in a Quarterly Report.
AMC Truist Invest Program
The AMC Truist Invest Program is an automated electronic discretionary investment advisory program offering
individualized investment recommendations by TAS Advisors for an asset-based fee. The AMC Truist Invest
Program is an automated electronic discretionary investment advisory program offering individualized investment
recommendations by TAS Advisors for an asset-based fee. Clients do not direct investment transactions for their
accounts enrolled in this Program. Instead, the AMC Truist Invest Program is offered by a TAS Advisor and
utilizes a computer algorithm (“Algorithm”) to generate projections and make discretionary investment decisions
separately for each Program account. The Algorithm also automatically periodically rebalances Program
accounts. The TAS Advisor is primarily responsible for making investment management recommendations, in
accordance with Client’s investment objectives related to one of the following goals: Retirement, Major Purchase
or General Investing and the type of portfolio which is limited in number and based on the Client’s risk tolerance.
Each Program account may only have a single selected goal.
In order to participate in the AMC Truist Invest Program, Clients are required to agree that records and disclosures
for the Program will be delivered, and agreements will be signed, electronically. This is an ongoing Program
requirement and includes Program disclosure brochures and other documents relating to Clients’ AMC Truist
Invest Program accounts. From time-to-time TAS will send Truist Invest Program Clients periodic e-mails
containing market commentary, alerts, evaluations, and other relevant content. Clients can opt out of the weekly
commentary, sales and reengagement and personalized guidance e-mails. After an AMC Truist Invest Program
account is opened Clients may not opt out of the standard transaction e-mails that notify them of events like
rebalancing, investment of cash or the annual review. If Clients refuse to accept electronic delivery of these
materials or are otherwise unable to or become unable to receive such materials, TAS will terminate Client’s AMC
Truist Invest account and Client will be required to transfer Client’s account assets to another account at TAS, TIS
or an account at another broker or financial institution or to liquidate their Truist Invest account. Clients must
maintain an accurate and up-to-date e-mail address with TAS to ensure that the Client has the ability to read,
download, print and retain applicable agreements, disclosure materials, and other documents and information
received from TAS. If a Client is unable or unwilling to accept electronic delivery the Client’s AMC Truist Invest
Program account will be terminated,
The investments available in the AMC Truist Invest Program consist of a limited number of IAG researched
Exchange Traded Funds (“ETFs”) offered through the Program and a core account sweep vehicle (described
below) and IAG asset allocation models upon which the Program’s investment portfolios are based. See Core
Account- TIS Sweep Program section above. The Algorithm that generates projections and investment
decisions based in part on IAG’ capital market assumptions, risk categories and asset allocation targets for those
categories. Adjustments may be made to the asset allocations in order to fit within the parameters of the Algorithm
by a member of the Digital Investing Group.
As TAS responsible for the discretionary management of the AMC Truist Invest Program and the Program
accounts, TAS has sole investment discretion related to (i) the selection of the Algorithm, which is sourced from
an independent third-party investment research and financial technology provider, (ii) the Program’s capital
markets assumptions, risk categories, asset allocation targets for those categories, (iii) eligible investment vehicles
for purchase for each asset class and (iv) the replacement, reduction or elimination of any investment vehicle in
the Program accounts.
Certain assets are ineligible for transfer into an AMC Truist Invest Program Account, such as fixed income
securities, limited partnerships, non-traded real estate investment trusts, etc.
AMC Truist Invest Program Account Funding with Existing Investment Positions
When a Client funds an AMC Truist Invest Program Account with existing securities positions (“Transferred
Securities”), the Algorithm performs an analysis on any mutual funds, ETFs and/or equity securities contributed
to the Program in kind and, based on internal and external costs such as internal advisory fees of mutual funds
and ETFs, trading costs associated with liquidations and potential tax implications, may retain some or all of the
Client’s existing shares of any such mutual fund, ETF and/or equity securities positions in a Client’s AMC Truist
Invest Program Account. However, Client’s should not expect that any of their Transferred Securities will
be selected by the Algorithm for retention and should instead anticipate any Transferred Securities used
to fund an AMC Truist Invest Program account will be sold and (i) that, in the case of taxable (non-IRA)
AMC Truist Invest Program accounts any applicable capital gains (or losses) associated with the
Transferred Securities will be realized and (ii) any contingent deferred sales charges associated with any
such Transferred Securities will be incurred when such shares are sold. Accordingly, Clients should
consult with their tax advisers prior to funding a taxable Truist Invest Program account with Transferred
Securities.
• TAS shall not be liable for any taxes or other expenses incurred in connection with the sale of any
Transferred Securities used to fund a Truist Invest Program account.
• Transferred Securities consisting of mutual fund or ETF positions into an account from another broker-
dealer will reflect TIS as the broker-dealer and as such, TIS may receive payments from the mutual fund
and/or ETF or their investment manager or distributor. See Other Fees or Charges section above.
• Fixed income securities cannot be transferred into an AMC Truist Invest Program account.
For any mutual funds transferred into and subsequently held in Truist Invest Program accounts, an advisory share
class is generally used if available. In certain circumstances, a different mutual fund share class may be utilized
if no equivalent advisory share class is available. Periodically, TAS will review account mutual fund positions and
convert existing mutual fund shares to advisory class shares, when available, without further notification to Clients.
Account Restrictions
Clients may discuss with their TAS Advisor any reasonable restrictions which they may wish to place on their
Program account and may direct that certain Transferred Securities be held in a separate brokerage account so
that such securities will not be liquidated by the Program without the Client’s consent. Clients may also request
that certain Program ETFs be excluded from their Program Account but not all requested restrictions can be
accepted. Unreasonable restrictions requested include directions to invest in securities, other than Transferred
Securities and the Program’s ETFs. A restriction which excludes one or more of the Program’s ETFs from a
Program account can impair the level of diversification available to the Program account and cause delays in the
management of the account. TAS will inform the Client if their Program account cannot be managed with the
requested investment restrictions and may suggest other available advisory programs offered by TAS as
alternatives.
Other
TAS does not have any soft-dollar arrangements.
METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
All AMC Programs
Investing involves risks, including fluctuating returns and potential loss of principal that Clients should be prepared
to bear.
Wash Sales: Clients with accounts across programs and different Investment Managers can experience a sale of
a security in one program account by the Investment Manager while purchasing the same security within another
program account managed by a different Investment Manager in a relatively short amount of time. None of TAS,
Envestnet or any Investment Manager coordinates trades to avoid a possible wash sale transaction.
AMC Advise and AMC Allocation Plus Programs
In providing recommendations, the Advisor implements specific security selections, subject to guidelines
established by TIS/TAS Policy Committee, based on research obtained by us from other sources.
In managing AMC Advise accounts, the Advisor will follow general portfolio construction guidelines established by
TIS/TAS Policy Committee concerning asset allocation, position diversification, and fixed income components.
The Advisor implements specific security selections based on research obtained by TAS from other sources.
The guidelines could restrict or limit the activity in an account. In addition, the program guidelines could change
at our discretion or could be waived under certain circumstances for certain Clients. Such changes to the
guidelines could result in investment activity and/or holdings deviating from the guidelines requiring action on the
Client’s part. If a Client decides not to take the requested action, we reserve the right to terminate the Client’s
account. In such instances, the account converts to a regular commission brokerage account.
TAS and its Advisors managing Client portfolios can utilize research reports and/or models created by TAS’
Investment Advisory Group. A conflict exists when TAS Advisors use the same models that TAS IAG use for
managing the TAS AMC program portfolios. See Conflict of Interest – Models Created by IAG for Management
of AMC Program Portfolios and TAS Advisor Usage of the Models for Client Portfolio Management Section
and Conflicts of Interest – Research Reports Created by IAG and Used by TAS Advisors and Affiliated
Firms Section above for details.
TAS also uses research provided by Credit Suisse First Boston (“CSFB”), Morningstar, NFS, Envestnet, Argus,
Value Line, Moody’s, Standard & Poor’s, Evercore ISI, Zacks, Fitch, CFRA, TSI and a variety of other research
providers. Some research provided by CSFB or NFS might not be fully disinterested to the extent that it concerns
companies with which CSFB or NFS has, or hopes to have, an investment banking or other business relationship
and thus has a conflict of interest in evaluating the companies' securities. Such research can also concern
securities for which CSFB or NFS is a market maker and thus has a conflict of interest. The exact composition
and asset allocation of each Client portfolio can differ depending on a variety of factors, including the Client’s
specific investment goals, the Client’s risk tolerance, and overall economic and market conditions.
In addition, firm approved alternative investments are available on the unaffiliated iCapital Network and CAIS
platforms.
The firm’s IAG conducts the initial and ongoing reviews of networks and platforms utilized in offering its AMC
programs to Clients. Offerings to be placed on the TAS AMC platform are submitted to the TIS/TAS Product
Working Group prior to being made available.
Advisors can also conduct their own research with approved research providers and are required to maintain
documentation related to the research conducted and followed. A conflict exists when certain TAS Advisors use
TAS research while others do not. See Conflict of Interest Research Reports Created by IAG Not Used by
Certain TAS Advisors, Section above for details.
Bonds: Investments in bonds are subject to risks. The most significant risk is interest rate risk. Generally, when
interest rates rise, bond values fall, values rise when interest rates decline. Other risks include default risk, or the
possibility the issuer will default on the payment of interest and/or principal; call risk, or the possibility the issuer
will redeem the bond before maturity; and inflation risk, or the possibility that inflation will outpace the bond’s
return.
Brokered Certificates of Deposit (“CDs”): All brokered CDs will fluctuate in value between purchase date and
maturity date. CDs can be sold on the secondary market prior to maturity subject to market conditions, which can
be limited. Any CD sold prior to maturity can be subject to a substantial gain or loss. The original face amount of
the purchase is not guaranteed if the position is sold prior to maturity. If a CD has a call provision, the issuer has
sole discretion whether to call the CD. If an issuer calls a CD, there is a risk to the investor that the investor will
be forced to reinvest at a less favorable interest rate.
Closed-end Funds: The value of any closed-end fund will fluctuate with the value of the underlying securities and
the market price for the fund’s shares, which can trade at a premium or discount to net asset values. Clients should
consider the investment objectives, risks and charges of a closed end fund carefully before investing. Please read
the prospectus carefully prior to investing.
Dollar Cost Averaging: Regular investing does not assure a profit or protect against a loss in declining markets.
Dollar Cost Averaging involves continuous investments in securities regardless of fluctuating price levels. Clients
should consider their financial ability to continue purchases through periods of low-price levels.
Exchange-Traded-Funds: Exchange-Traded-Fund (“ETFs”) values will fluctuate so that an investor’s shares, when
sold, can be worth more or less than their original cost. The value of any ETF will fluctuate with the value of the
underlying securities and the market price for the fund’s shares, which can trade at a premium or discount to net
asset values. Clients should consider the investment objectives, risks and charges of an ETF carefully before
investing. Please read the prospectus carefully prior to investing.
Floating Rate Funds: Securities with floating interest rates generally are less sensitive to interest rate changes but
can decline in value if their interest rates do not rise as much, or as quickly, as prevailing interest rates. Unlike
fixed-rate securities, floating rate securities generally will not increase in value if interest rates decline. Changes
in interest rates also will affect the amount of interest income the Fund earns on its floating rate investments.
Floating rate securities involve liquidity risk, which can affect the ability of investors to buy and sell them at the
desired time or price.
Margin: Margin trading is not appropriate for all Clients and involves material risk. Margin is only allowed in the
AMC Allocation Plus Program. Clients can lose more funds than they have deposited in the margin account; the
firm providing margin credit (NFS) can force the sale of securities or other assets in the account(s); the firm can
sell securities or other assets without contacting Clients; Clients are not entitled to choose which securities or
other assets in their account are liquidated or sold to meet a margin call; the firm can increase in-house
maintenance requirements at any time; and Clients are not entitled to an extension of time on margin call. Market
conditions can magnify any potential for loss. If the market turns against a Client, the Client will be required to
deposit additional securities and/or cash in the account. The interest rates charged are determined by the value
of the cash and securities prior to initiating the loan.
Money Market Mutual Funds: An investment in a money market fund is not insured or guaranteed by the FDIC or
any other government agency. Although the money market fund seeks to preserve the value of your investment
at $1.00 per share, it is possible to lose money by investing in in a money market fund.
Mutual Funds: Mutual Fund values will fluctuate so that an investor’s shares, when redeemed can be worth more
or less that their original cost Client should carefully review the fund’s prospectus and consider the investment
objectives, risks and charges and expenses of the investment company carefully before investing.
Options: Option trading entails significant risk and is not suitable for all investors. For a current options disclosure
document, Clients can call the TAS Centralized Supervision Group, 804.594.1167. Clients should consult with
their tax advisor in order to determine tax implications of options transactions. Supporting documentation for any
claims, if applicable, will be furnished upon request.
Private Offerings – Alternative Investments: Investments in private offerings, particularly those related to
alternative investments such as hedge funds, fund of funds, opportunity zone funds are considered long-term
investments due to their illiquid nature. These investments are generally not registered and certain information
such as audited financials are not always required. Fees assessed on these securities are often based on book
values which is sometimes delayed.
Opportunity Zone Funds can incur additional risks if they do not continue to meet the requirements for certain tax
considerations and investors could be negatively impacted in the event that an Opportunity Zone Fund shall fail
to qualify for preferential tax treatment.
Unit Investment Trust: The value of any UIT will fluctuate with the value of the underlying securities and market
conditions.
AMC Annuity
In providing recommendations, the Advisor implements or recommends the initial sub-account portfolio and makes
ongoing recommendations as needed, subject to guidelines established by TIS/TAS Policy Committee. In
managing accounts, the Advisor will follow general portfolio construction guidelines established by TIS/TAS Policy
Committee concerning asset allocation in the sub-accounts available on the carrier’s platform and will make
ongoing recommendations as needed.
Annuities: The firm prohibits commission based transactional annuities being linked to managed accounts.
However, AMC Annuity Program commission waived annuities can be linked to AMC Allocation Plus (AL) accounts
for billing purposes.
Annuities with investments in the following security types are subject the following risks.
Exchange-Traded-Funds: Exchange-Traded-Fund (“ETFs”) values will fluctuate so that an investor’s shares, when
sold, can be worth more or less than their original cost. Clients should consider the investment objectives, risks
and charges of an ETF carefully before investing. Please read the prospectus carefully prior to investing.
Mutual Funds: Mutual fund and values will fluctuate so that an investor’s shares, when redeemed can be worth
more or less that their original cost, Client should carefully review the fund’s prospectus and consider the
investment objectives, risks and charges and expenses of the investment company carefully before investing.
TAS relies on TIS to conduct due diligence on the available annuity carriers and annuities in the AMC Annuity
program. See “Other Financial Industry Activities and Affiliations” below.
AMC Pinnacle and AMC Pinnacle – Sleeve Select, Advisor Managed Discretionary Sleeve
In providing recommendations and making discretionary investment decisions in connection with the AMC
Pinnacle or AMC Pinnacle – Sleeve Select, Advisor Managed Discretionary Sleeve, the TAS Advisor managing
this Sleeve of the Program implements specific security selections, subject to guidelines established by TIS/TAS
Policy Committee concerning asset allocation, economic sectors and position diversification, and fixed income
components. The Advisor implements specific security selections based on research obtained by TAS from other
sources.
AMC Pinnacle and AMC Pinnacle – Sleeve Select, Advisor Non- Discretionary Sleeve.
In providing recommendations in connection with the AMC Pinnacle or AMC Pinnacle – Sleeve Select, Advisor
Non-Discretionary Sleeve, the TAS Advisor managing this Sleeve of the Program makes specific security
recommendations subject to guidelines established by TIS/TAS Policy Committee concerning asset allocation and
position diversification.
TAS and its Advisors can utilize models created by TAS’ IAG for either sleeve, Advisor Managed Discretionary or
Advisor Non-Discretionary. A conflict exists when TAS Advisors use or recommend the same models that TAS IAG
use for managing the TAS AMC program portfolios. See Conflict of Interest – Models Created by IAG for
Management of AMC Program Portfolios and TAS Advisor Usage of the Models for Client Portfolio
Management Section and Conflicts of Interest – Research Reports Created by IAG and Used by TAS
Advisors and Affiliated Firms sections above for details.
TAS also uses research provided by Credit Suisse First Boston (“CSFB”), Morningstar, NFS, Argus, , Value Line,
Moody’s, Evercore ISI, Zacks, Fitch, CFRA, DBRS, TSI and a variety of other research providers. Some research
provided by CSFB or NFS might not be fully disinterested to the extent that it concerns companies with which
CSFB or NFS has, or hopes to have, an investment banking or other business relationship and thus has a conflict
of interest in evaluating the companies' securities. Such research can also concern securities for which CSFB or
NFS is a market maker and thus has a conflict of interest. The exact composition and asset allocation of each
Client portfolio can differ depending on a variety of factors, including the Client’s specific investment goals, the
Client’s risk tolerance, and overall economic and market conditions. See Conflict of Interest –Different Advice
section above below for details.
AMC Fund Select Tactical and AMC Fund Select Tactical Focus
TAS’ IAG maintains various mutual fund and ETF asset allocation models for these Programs and utilizes various
research providers related to the market and investment vehicles.
In addition, TAS has agreements with Third Party Model Portfolio Providers for their investment models. TAS’ IAG
utilizes various research providers related to the initial and ongoing due diligence conducted on the Third Party
Managers in the program.
Exchange-Traded-Funds: Exchange-Traded-Funds values will fluctuate so that an investor’s shares, when sold,
can be worth more or less than their original cost. Clients should consider the investment objectives, risks and
charges of an ETF carefully before investing. Please read the prospectus carefully prior to investing.
Mutual Funds: Mutual Fund values will fluctuate so that an investor’s shares, when redeemed can be worth more
or less that their original cost. Client should carefully review the fund prospectus and consider the investment
objectives, risks and charges and expenses of the investment company carefully before investing.
Money Market Mutual Funds: An investment in the Fund is not insured or guaranteed by the FDIC or any other
government agency. Although the Fund seeks to preserve the value of Client’s investment at $1.00 per share, it
is possible to lose money by investing in the Fund.
Dollar Cost Averaging: Regular investing does not assure a profit or protect against a loss in declining markets.
Dollar Cost Averaging involves continuous investments in securities regardless of fluctuating price levels. Clients
should consider their financial ability to continue purchases through periods of low-price levels. Client should
review the prospectus for availability of periodic investments.
AMC Premier
AMC Premier is a separately managed account program where TAS has contracted with third-party investment
managers to manage Client assets. TAS is also a manager available within the AMC Premier Program. TAS’ IAG
utilizes various research providers related to the initial and ongoing due diligence conducted on the Managers in
the program.
Mutual Fund Share Class Selection: The Third Party Manager, which has been delegated complete discretionary
authority, is solely responsible for determining the appropriate mutual fund share class for Client accounts enrolled
in this Program. TAS does not review share classes utilized by Third Party Managers and will not change share
class of any mutual fund in Client accounts managed by Third Party Mangers.
Margin: Margin trading is not appropriate for all Clients and involves material risk. You can lose more funds than
you have deposited in the margin account; your margin provider can force the sale of securities or other assets in
your account(s); the your margin provider can sell your securities or other assets without contacting you; you are
not entitled to choose which securities or other assets in your account are liquidated or sold to meet a margin call;
your margin provider can increase in-house maintenance requirements at any time; and you are not entitled to an
extension of time on margin call. Market conditions can magnify any potential for loss. If the market turns against
the investor, he or she will be required to deposit additional securities and/or cash in the account. The interest
rates charged are determined by the value of the cash and securities prior to initiating the loan.
TAS’ IAG provides the initial and on-going due diligence on the Third Party Managers and Third Party Model
Providers used in the Program and makes recommendations to TIS/TAS Product and Platform Committee related
to such due diligence. The TIS/TAS Product and Platform Committee reviews and either approves or rejects the
recommendations made by IAG.
For the Envestnet Sentry Program, TAS contracted with Envestnet who conducts due diligence on the Approved
Envestnet Managers in the Program.
AMC Truist Invest
TAS’ IAG maintains the strategic asset allocation and investment product recommendations for the AMC Truist
Invest Program and utilizes various research providers related to the market and investment vehicles.
Information Sources: The main information sources for market statistics, financial, and other performance data on
which the Program relies are third party data vendors. TAS pays these vendors access fees for their data
services. If any of the information listed above is erroneous or disrupted in any way, Client’s AMC Truist Invest
Program account may experience losses.
Reliance on Client Information: Client is responsible for providing true, accurate, and complete information to
TAS and to promptly notify TAS whenever there are changes to this information that could affect TAS’s projections
or investment decisions, our ability to communicate with Client, or other personalized aspects of the Program.
Such changes may include the addition of a new investment account, a life-change event that affects a Client’s
investment horizon, or a change to Client’s e-mail address. If a Client does not supply truthful, timely and accurate
information, the quality and applicability of TAS’s goal projections and investment decisions may be compromised,
which may prevent the Program from helping the Client achieve their financial and/or retirement goals. In addition,
the Program does not consider in its analysis accounts and assets that are not entered into a Client’s Client profile.
In any or all of these circumstances when information provided by the Client to the Program is incomplete or
inaccurate, Client’s AMC Truist Invest Program account may experience losses.
Risk of Reliance on Third Party Data: AMC Truist Invest Program services are highly reliant on data from third
party and other external sources, and discretion will be exercised to determine what data to gather, which may
have an impact on the Program’s projections and decisions. In addition, due to the automated nature of data
gathering and the fact that much of this data comes from third party sources, not all desired and/or relevant data
will be available to, or processed by, TAS at all times. Certain data or data types may not be utilized in generating
or making goal projections and/or investment decisions, and data that is actually utilized may not be the most
accurate data and may contain errors. In any or all of these instances, Client’s AMC Truist Invest Program account
may experience losses.
Risk of Third-Party Reliance: TAS relies on third parties to provide significant and fundamental aspects of the
AMC Truist Invest Program, including the Algorithm and the resulting financial and/or retirement projections,
investment decisions, and operating platform. TAS relies on third parties for provision of market statistics,
aggregated account information, fund details, and other performance-related information. Although TAS generally
considers their third-party vendors and other service providers to be reliable, errors beyond TAS’ control could
compromise the information and/or services they provide, and in turn, the quality and integrity of the AMC Truist
Invest Program’s projections and decisions. In addition, certain service providers have the right to terminate their
agreements with TAS at their absolute discretion. Others service providers may experience operational
disruptions due to unforeseen circumstances. In any or all of these instances, Client’s AMC Truist Invest Program
account may experience losses.
Risks of the Algorithm: The AMC Truist Invest Program depends on investment decisions generated significantly
by the Algorithm. The Algorithm is automated and will only be customized within its limitations, which include the
capital markets assumptions, risk categories, asset allocation targets for those categories, target portfolios and
eligible investment vehicles for each asset class that TAS provides, and the information Client supplies related to
their Client profile. If the Algorithm were to malfunction or fail, or were to rely on assumptions, including economic
and transaction cost assumptions, that are incorrect, that do not apply to Client’s specific financial situation, or
that do not change even as market expectations shift, Client could sustain investment losses, some or all of which
could be significant. Additionally, the Algorithm employs a number of quantitative models that involve assumptions
based upon a limited number of variables that may be extracted from complex financial markets or instruments
that they are intended to replicate. The Algorithm may rebalance Client accounts without regard to market
conditions, or on a more frequent basis than might be expected in the case of a non-automated investment
program. Any one or all of these assumptions, whether or not supported by past experience, could prove over
time to be incorrect, which could cause Client’s AMC Truist Invest Program account to experience losses.
Model Risk: Models and techniques deployed by the AMC Truist Invest accounts are based on the information
and data available as well as on assumptions, assessments, and estimates developed by TAS, all of which may
be subject to error. As a result, those models and techniques may not account for all relevant factors or may not
account for any such factors correctly. More generally, there can be no assurance that such models and
techniques will be effective. In any or all of these instances, Client’s AMC Truist Invest Program account may
experience losses.
Capital Markets Assumptions: The assumed risk, return, volatility, and correlation of the asset classes
corresponding to Client’s declared risk tolerance and time horizon used to develop the Client’s investment forecast
are based on the capital markets assumptions specified by TAS. Those assumptions, which are based on
historical asset class returns (as reflected by certain indices), proprietary models, subjective assessments of the
current market environment, and forecasts of likelihood of future events, may turn out to be incorrect, which may
cause the Client to accept more or less risk than Client desired and undermine the AMC Truist Invest Program’s
ability to help Client reach their financial and/or retirement goals. In any or all of these instances, Client’s AMC
Truist Invest Program account may experience losses.
Correlation Risk: Certain investments made by AMC Truist Invest will experience returns that individually or in
the aggregate are correlated (possibly highly) with various market indices, including various equity, debt or other
markets around the world. In different market conditions and time periods, however, there may be periods of time
when Client’s AMC Truist Invest Program account returns are not correlated with various market indices or the
returns of other investment strategies. In any or all of these instances, Client’s AMC Truist Invest Program account
may experience losses.
Diversification and Asset Allocation Risk: The AMC Truist Invest Program’s target asset allocations are
constructed using modern portfolio theory, which seeks to construct portfolios to optimize expected return based
on a given level of market risk and is based on the risk and return characteristics and relationships of the asset
class exposures, as dictated by TAS’ capital market assumptions. The asset classes selected by TAS are intended
to reflect the types of fundamental equity and fixed income exposures that are commonly included within
diversified investment portfolios. Other asset classes not considered in the Program’s portfolios may have
characteristics similar or superior to those that are included. Diversification does not eliminate all investment risks
and in particular does not eliminate market risk. Client’s AMC Truist Invest Program account may experience
losses due to market risk or ineffective diversification.
In addition, the asset classes selected can perform differently from each other at any given time (as well as over
the long term), so the Client’s AMC Truist Invest Program account’s performance will be affected by the allocation
among the various asset classes. The AMC Truist Invest Program’s asset allocation decisions may result in more
portfolio concentration in a certain asset class or classes, which could reduce overall return if the concentrated
assets underperform AMC Truist Invest’ Programs expectations. Depending on market conditions, there may be
times where diversified portfolios underperform less diversified portfolios, as diversification and asset allocation
strategies do not guarantee low volatility, profit, or protection against investment loss. In any or all of these
instances, Client’s AMC Truist Invest Program account may experience losses.
Moreover, the value of an entire asset class can decline for a variety of reasons outside of TAS’ control, including,
but not limited to, changes in the macroeconomic environment, unpredictable market sentiment, forecasted or
unforeseen economic developments, technological innovations, interest rates, regulatory changes, and domestic
or foreign political, demographic, or social events. A high allocation in a particular asset class may negatively
affect Client’s overall AMC Truist Invest Program account performance to the extent that the asset class
underperforms relative to other market assets. Conversely, a low allocation to a particular asset class that
outperforms other asset classes in a particular period will cause Client’s account to underperform relative to the
overall market. In any or all of these instances, Client’s AMC Truist Invest Program account may experience
losses.
Portfolio Construction: Focus is placed on selecting ETFs to implement the AMC Truist Invest Program’s
investment strategy by utilizing a thorough due diligence process that seeks to identify those ETFs that are best
positioned to help Clients achieve retirement or other financial goals with an appropriate risk level and lower costs.
The selection process incorporates factors such as investment methodology, performance history, liquidity, fee
structures and other costs, as well as the role an investment can play to deliver a Client’s target asset allocation
strategy. If TAS is materially ineffective in providing these services, Client’s AMC Truist Invest Program account
may experience losses.
Exchange-Traded-Funds: Exchange-Traded-Funds values will fluctuate so that an investor’s shares, when sold,
may be worth more or less than their original cost. Clients should consider the investment objectives, risks and
charges of an ETF carefully before investing. Please read the ETF’ prospectus carefully prior to investing.
Investing in securities, including ETFs, involves risk of loss that the Client should understand and be prepared to
bear.
Investment performance can never be predicted or guaranteed, and the value of Clients AMC Truist Invest
Program account will fluctuate due to market conditions and other factors. Client’s AMC Truist Invest Program
account may experience losses.
Past performance is no guarantee of future results.
Advisory Account Funding Risk: The sale or liquidation of any investment or other asset to fund a Client’s AMC
Truist Invest Program account may have adverse tax consequences, early withdrawal penalties, or other costs or
penalties as a result of such sale or liquidation, including the loss of living, death, or other benefits of that
investment or asset. In addition, if a Client funds a AMC Truist Invest Program account with existing securities,
the liquidation of those securities by the Program may have similar effects.
Tax Risks: While the Algorithm includes a component that seeks to achieve tax optimized asset placement, which
is designed to help optimize the Client’s portfolio by allocating less tax-efficient assets into tax-advantaged
accounts, this component is only one of many that should comprise a Client’s comprehensive tax management
plan, and supplementary tax advice that is outside the AMC Truist Invest Program’s scope may be necessary to
minimize the impact of tax liabilities that Client could incur through the Program. Any tax optimized decisions
implemented is not intended to serve as tax advice, and no representation is made that a Client will obtain or
avoid any particular tax consequences as a result of those decisions. Dividends, capital gains, transfers, and
sales of securities will create taxable events unless Client’s account is tax-exempt (e.g., an individual retirement
account). Clients are urged to consult with their personal tax and legal advisors regarding the tax consequences
of investing in an AMC Truist Invest Program account based on Client’s particular circumstances. TAS does not
assume responsibility to Client for the tax consequences of any transaction.
In addition, any tax-loss harvesting (i.e., offsetting capital gains with capital losses in order to reduce or eliminate
income tax obligations) implemented by the Algorithm should not be interpreted as tax advice, and no
representation is made that certain tax consequences will be obtained or that the associated investment decisions
will result in any particular tax consequences. The tax consequences of tax-loss harvesting, and other tax
optimized strategies are complex and may be challenged by the Internal Revenue Service. Moreover, investment
decisions associated with such strategies may not perform as expected; expected returns and risk characteristics
are no guarantee of actual performance. The AMC Truist Invest Program was not developed to be used by, and
it cannot be used by, any Client to avoid tax penalties or interest.
Withdrawal Risk: Cash withdrawals from, or other changes to, a Client’s AMC Truist Invest Program account may
cause trades sent for execution at then-prevailing market prices or prevent TAS from executing other trades
intended to rebalance a Client’s investment portfolio, resulting in the Client’s current asset allocation deviating
from the target asset allocation and losses, undermining the Client’s long-term financial goals. Further, dividend
and other income generated by the securities held in a Client’s AMC Truist Invest Program account will be used
to rebalance that account, will not necessarily be reinvested in those same securities, and will not be made
available for withdrawal. In any or all of these instances, Client’s AMC Truist Invest Program account may
experience losses.
Technology and Cybersecurity Risk: The AMC Truist Invest Program depends on various computer and
telecommunication technologies, many of which are provided by or are dependent on third parties. The ability of
TAS, Truist Bank, TIS and the Site to successfully operate could be severely compromised by system or
component failure, delays in data transmission to an executing broker , telecommunication failure, power loss, a
software-related system crash, unauthorized system access or use (such as “hacking”), computer viruses, worms,
and similar programs, fire or water damage, human errors in using or accessing relevant systems, or various other
events or circumstances. These events may impact trading in a Client’s AMC Truist Invest Program account. It
is not possible to provide comprehensive and foolproof protection against all such events, and no assurance can
be given about the ability of applicable third parties to continue providing their services. As an automated,
algorithmic investment advisory service, any event that interrupts the AMC Truist Invest Program’s computer
and/or telecommunication systems or operations could compromise the AMC Truist Invest Program for an
extended time period and cause a Client’s AMC Truist Invest Program account to experience losses, including by
preventing trading, modifying, liquidating, and/or monitoring the Client’s investments. In addition, there are
information security and related risks associated with the use of electronic, internet-based technologies to provide
the AMC Truist Invest Program. In general, cyber incidents can result from deliberate attacks or unintentional
events and are not limited to, gaining unauthorized access to digital systems, and misappropriating assets or
sensitive information, corrupting data, or causing operational disruption, including denial-of-service attacks on
websites. Cybersecurity failures or breaches affecting the AMC Truist Invest Program, or its third-party vendors,
have the ability to cause disruptions to the AMC Truist Invest Program, potentially causing Client accounts to
experience financial losses, the inability to access AMC Truist Invest Program, and/or other damages.
Operational Risk: A Client’s AMC Truist Invest Program account may experience losses as a result of
shortcomings or failures in TAS’ internal processes, people, or systems, or from external events. Such operational
risks can arise from many factors ranging from routine data processing errors to potentially costly incidents related
to, for example, major information technology systems failures. Any operational shortcomings or failures that are
outside the scope of TAS’ disaster recovery and business continuity plans may result in AMC Truist Invest
Program disruptions or contribute to AMC Truist Invest Program account losses. A copy of TAS’ recovery and
continuity plan is available upon request.
Market Risks: Trades sent to an executing broker on behalf of TIS and TAS may be impacted by the following
market risks, any or all of which may cause Client’s AMC Truist Invest Program account to experience losses:
Market Order Risks: Equity and ETF trades in a AMC Truist Invest Program account will generally be executed
using “market orders,” which execute immediately at the best available current price. These orders have higher
risks than those orders that specify a target price at which a trade should execute and remain open for a longer
time period (i.e., “limit orders”), particularly during periods of high volatility and for securities with low liquidity. As
a result, the use of “market orders” could cause Client to potentially pay a higher price for securities purchased
with these orders or receive a lower sale price, while also increasing transaction costs. However, in such
circumstances, other order types and conditions may be used, as appropriate, to achieve best execution.
Liquidity and Valuation Risk: High volatility and/or the lack of deep and active liquid markets for a security may
prevent trades for Clients at all, or at an advantageous time or price. Some securities (including ETFs) that hold
or trade derivatives and/or other financial instruments may be adversely affected by liquidity issues as they
manage their portfolios. NFS conducts the valuation of assets in Client AMC Truist Invest Program accounts and
TAS believes the values to be reliable, but TAS will not verify the accuracy of the information, see FEES:
Valuation section above.
Volatility Risk: The performance of investment strategies AMC Truist Invest Program deploys may be volatile
(both in absolute terms and relative to realized returns), potentially resulting in increased risks, including the risk
of losses. Investments may have volatility, variability of return outcomes, lower average returns, correlation with
certain macroeconomic risks, asset class concentrations, and/or other significant risks, whether in absolute terms,
relative to expected returns, or relative to certain other strategies that are deployed by TAS on behalf of other
Clients.
Risk of Trading Suspensions: During periods of extraordinary market volatility or illiquidity, or at other times when
suspension of trading is deemed to be in the best interests of Clients, TAS in the exercise of its own discretion,
may suspend directing trades to NFS with respect to a Client’s AMC Truist Invest Program account. A trading
suspension could cause a Client’s asset allocation to deviate from target, or prevent the Client from liquidating
their account. While TAS will make the decision to institute a trading suspension based on its consideration of
what is in Client’s best interest in light of then-prevailing market conditions, suspensions could nonetheless have
unintended consequences that TAS are unable to anticipate.
Financial Market Disruptions: Disruptions in the global financial markets have historically had materially adverse,
and in certain cases catastrophic, consequences for the values, liquidity, and stability of certain types of
investments, including the types of investments that are recommended in the Program’s portfolios and made on
the Client’s behalf in the AMC Truist Invest Program account. Similar or dissimilar disruptions may occur in the
future, and their duration, severity, and ultimate effect are difficult to forecast. These disruptions could lead to
additional regulations or laws, which could have a material adverse effect on Client’s AMC Truist Invest Program
account.
Economic Risk: A Client’s AMC Truist Invest Program account’s investments are likely to be exposed to risks
relating to weakness in various global economies and the economic cycle. Numerous factors, such as market
volatility, interest rates, commodity prices, equity prices, currency prices, credit spreads, and deflationary and
inflationary pressures, may be affected by the economic cycle and long-term economic trends. Predictions about
financial market conditions and economic factors are highly uncertain, and the presence, duration, and impact of
any market or economic conditions could have a materially adverse effect on AMC Truist Invest Program account
investments.
Regulatory Change Risk: It is possible that changes in applicable laws and regulations will affect a Client’s AMC
Truist Invest Program account. These changes may include changes in investment adviser or securities trading
regulation (or the interpretation of existing laws and regulations) and changes in the tax code that could affect
interest income, income characterization, and/or tax reporting obligations. In addition, a number of substantial
regulatory changes are pending or in the process of changing in certain markets. The consequences of additional
regulation on the liquidity and the efficient and orderly functioning of the markets in which investments held and/or
purchased in AMC Truist Invest Program accounts cannot be predicted and may materially diminish the
profitability of a Client’s AMC Truist Invest Program account and may cause the Client’s AMC Truist Invest
Program account to experience losses.
While the services described in this brochure attempt to optimize investment returns for a Client risk tolerance,
TAS does not make any assurance that the investment recommendations and/or decisions will be successful and
result in profitable investing. Client’s AMC Truist Invest Program account may experience losses.
VOTING CLIENT SECURITIES
AMC Allocation Plus: With respect to the AMC Allocation Plus Program TAS has no authority or obligation to
take any action or render any advice with respect to the voting of proxies solicited by or with respect to issuers of
securities in which assets can be invested from time to time. Client expressly retains the authority and
responsibility for the voting of such proxies. Client will receive all shareholder communications, including proxy
statements and proxies, distributed by the issuers of securities held in Client accounts.
AMC Advise Accounts: TAS will vote proxies for accounts enrolled in the AMC Advise Program, including assets
that are held and not managed, unsupervised assets. TAS is responsible for establishing policies and procedures
designed to enable TAS to ethically and effectively fulfill its fiduciary obligation to vote all applicable proxies on
behalf of the Client accounts and funds.
AMC Premier Program and Envestnet Sentry Program Accounts: For accounts managed by a third-party
manager, TAS has no authority or obligation to take any action or render any advice with respect to the voting of
proxies solicited by or with respect to issuers of securities in which assets can be invested from time to time. The
manager or Client expressly retains the authority and responsibility for the voting of such proxies. The manager
generally will receive all shareholder communications, including proxy statements and proxies, distributed by the
issuers of securities held in Client accounts without forwarding the same to Clients. Clients should review the
manager’s brochure for specifics regarding the manager’s voting policies.
For accounts managed by TAS, TAS will vote proxies, including assets in an account that are not managed,
unsupervised assets.
AMC Truist Invest: With respect to the AMC Truist Invest Program, TAS will vote proxies unless a Client delivers
a written request to TAS to exempt the Client’s Program Account from this process. If such requested is provided,
TAS will cause the applicable proxies to be forwarded to the Client.
AMC Fund Select Tactical and AMC Premier– Fidelity Charitable Accounts: TAS has no authority or obligation
to take any action or render any advice with respect to the voting of proxies solicited by or with respect to issuers
of securities in which assets are invested from time to time. Fidelity Charitable retains the right to vote proxies.
AMC Fund Select Tactical, AMC Fund Select Tactical Focus, AMC Pinnacle and AMC Pinnacle – Sleeve
Select: With respect to each of these Programs TAS will vote proxies, including assets in an account that are not
managed, unsupervised assets. TAS is responsible for establishing policies and procedures designed to enable
TAS to ethically and effectively fulfill its fiduciary obligation to vote all applicable proxies on behalf of the Client
accounts and funds.
Annually (or more often as needed), TAS will review, reaffirm and/or amend guidelines, strategies and proxy
policies for all Client accounts.
Although TAS does its best to alleviate or diffuse known conflicts, there is no guarantee that all situations have
been or will be mitigated through proxy policy implementation. TAS relies on Truist Bank’s annual reviews of Glass
Lewis’ size, experience and technical capabilities. TAS contracts with Glass Lewis & Co. as its agent to provide
policy recommendations, vote Firm proxies, assist us with certain administrative, clerical, functional recordkeeping
and support services related to the Firm’s proxy voting processes/procedures, which include, but are not limited
to:
1. Access to proxy research,
2. Custom policy recommendations,
3. The collection and coordination of proxy material from the custodian for each TAS Client’s account(s),
4. Proxy voting, reconciliation, and disclosure for each of TAS Client’s account(s), in accordance with
TAS’ proxy policies,
5. Required record keeping and voting record retention of all TAS proxy voting on behalf TAS’ Clients.
To obtain a copy of the complete proxy voting policies and procedures, or information about how TAS voted Client
proxies, please contact: Truist Advisory Services, Inc. Attn: Advisory Program Manager, 303 Peachtree Center
Avenue, Truist Garden Offices, Suite 140, Atlanta, GA 30303.
CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS
TAS Advisor Managed Programs
AMC Advise Advisors have access to all Client information.
The AMC Allocation Plus and AMC Annuity programs are Client directed and Advisors do not have discretionary
authority to implement changes without Client consent. Advisors have access to all Client information.
AMC Fund Select Tactical, AMC Fund Select Tactical Focus, AMC Pinnacle, AMC Pinnacle – Sleeve Select
and AMC Premier Model
When new account documentation is approved, TAS submits the documentation, including the Client profile that
identifies the Client’s goals, risk tolerance, time horizon, financial situation and other factors to the Platform
Manager for inclusion in the Program.
AMC Pinnacle, AMC Pinnacle – Sleeve Select, AMC Premier SMA Program Accounts and Envestnet Sentry
Accounts
When new account documentation is approved, TAS submits the documentation, including the Client profile that
identifies the Client’s goals, risk tolerance, time horizon, financial situation, selected Manager(s) and other factors
to the Platform Manager for inclusion in the Service.
Managers are sent information on the Client’s financial circumstances, investment goals and objectives and any
special instructions the Client might wish to give the Manager regarding the account.
Updates or changes to Client information, including financial information, objectives, risk tolerance, among other
items are communicated to the administrator for system updates.
AMC Truist Invest
TAS and the TAS Advisor of an AMC Truist Invest Program account have access to all Client information.
CLIENT CONTACT WITH PORTFOLIO MANAGERS
AMC Allocation Plus, AMC Advise, AMC Annuity and AMC Truist Invest
The TAS Advisor has direct contact with their Clients.
AMC Fund Select Tactical, AMC Fund Select Tactical Focus, AMC Pinnacle AMC Pinnacle – Sleeve Select
(Advisor Managed Sleeves) and AMC Premier Model Accounts
The TAS Advisor has direct contact with their Clients.
AMC Premier and Envestnet Sentry Program Accounts
AMC Premier and Envestnet Sentry Clients do not generally interact directly with Manager personnel, but can do
so through TAS.
ADDITIONAL INFORMATION
DISCIPLINARY INFORMATION
On December 31, 2016, SunTrust Investment Services, Inc., now Truist Investment Services, Inc., an affiliate of
TAS, assigned substantially all of its existing investment advisory contracts to TAS. On September 14, 2017, the
U.S. Securities and Exchange Commission, (SEC) issued an administrative order against TIS instituting
administrative and cease-and- desist proceedings pursuant to Section 15(b) of the Securities Exchange Act of
1934 and Sections 203(e) and 203(k) of the Investment Advisers Act (IAA), making findings, and imposing
remedial sanctions and a cease-and-desist order (the “OIP”). According to the SEC, TIS did not adequately inform
its advisory Clients of the conflicts of interest presented by its representatives’ share class selections and the
receipt by TIS and its representatives of 12b-1 fees over the period 2011 to 2015. The SEC found that during this
period, TIS and its representatives received $1,148,071.77 in avoidable 12b-1 fees paid by the funds in which the
advisory Clients were invested. Without admitting or denying the SEC’s findings, TIS consented to the entry of the
OIP that censured TIS and found that TIS willfully violated and agreed to cease and desist from committing or
causing any future violations of Sections 206(2), 206(4), and 207 of the IAA and Rule 206(4)-7 promulgated
thereunder. The OIP imposed a civil monetary penalty of $1,148,071.77 upon TIS and required TIS to refund to
current and former Clients fees of $1,148,071.77 together with interest of $150,238.74.
On February 19, 2021, BB&T Securities LLC (“BBTS”) assigned substantially all of its existing investment advisory
contracts to TAS.
On August 25, 2016, without admitting or denying the findings, BBTS consented to the entry of an Order (File No.
3-17502) by the United States Securities and Exchange Commission (the “SEC”) Instituting Cease-and-Desist
Proceedings, Making Findings, and Imposing a Cease-and-Desist Order (the “Order”). The Order states that from
December 2, 2011, to October 1, 2013, in reliance on F-Squared Investments, Inc.’s (“F-Squared”) false
statements, BB&T Securities’ AlphaSector advertisements falsely stated that F-Squared had assets invested in
the AlphaSector strategy from April 2001 to September 2008, and that the track record for these investments had
significantly outperformed the S&P 500 Index during this period. The Order also states that BBTS took insufficient
steps to confirm the accuracy of F-Squared’s AlphaSector performance data for this period and failed to obtain
sufficient documentation to substantiate F-Squared’s advertised performance, resulting in BBTS violating Sections
206(4) and 204(a) of the Advisers Act and Rules 206(4)-1(a)(5) and 204-2(a)(16) thereunder. The Order requires
the Firm to cease and desist from committing or causing any violations of the above referenced provisions and to
pay a $200,000 penalty to the SEC.
BBTS has consented, without admitting or denying the findings, to the issuance of an administrative cease-and-
desist order by the SEC (the “Order”) issued on September 7, 2018. The Order includes findings that, during the
period between approximately March 2012, and July 2015, BB&T Investment Services, Inc. “BB&TIS”), which
merged into the Firm effective January 1, 2018, violated Section 206(2) of the Investment Adviser’s Act of 1940
(the “Adviser’s Act”) by failing to adequately disclose certain conflicts of interest relevant to its recommendation of
an affiliated adviser’s wrap fee program. Specifically, the Order finds that BB&TIS failed to disclose sufficient facts
to enable Clients to determine that a compensation arrangement between BB&TIS and the affiliated adviser
created an incentive for BB&TIS and its investment advisory representatives to recommend that Clients invest in
the affiliated adviser’s wrap fee program rather than two other available wrap fee programs. The Order orders the
Firm to cease and desist from any further violations of Section 206(2) of the Adviser’s Act and imposes a $100,000
penalty.
On March 5, 2019, without admitting or denying the findings, BBTS consented to the entry of an Order (File No.
3-19020) by the United States Securities and Exchange Commission (“SEC”) Instituting Administrative Cease-
and-Desist Proceedings, Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist Order
(“Order”). In late 2015, BB&T Corporation (“BB&T Corp.) acquired the parent entity of Valley Forge Asset
Management, LLC (“Valley Forge”), a former dually registered investment adviser and broker-dealer. Valley Forge
continued to operate independently until March 1, 2016, when it was merged into the Firm. The Order states that
from 2013 to 2016, Valley Forge made misleading statements in its Form ADV Part 2A and Exhibit 1 of its
Investment Advisory Contract regarding its Affiliated Brokerage program and failed to fully inform its Clients
regarding their brokerage choices. The Order further states that Valley Forge charged its Affiliated Brokerage
Clients higher commissions compared to those paid by Clients who used another directed brokerage option
available to Valley Forge Clients at the time. The Order notes that after Valley Forge was acquired, the Firm acted
to end the Affiliated Brokerage program, amended the cost structure, and amended its disclosures. The Order
states that, as a result of the conduct described above, Valley Forge willfully violated Sections 206(2) and 207 of
the Advisers Act. The Order requires the Firm to cease and desist from committing or causing any violations of
the above-referenced provisions, to pay disgorgement of $4,712,366 and prejudgment interest of $497,387, and
to pay a $500,000 penalty to the SEC.
On March 11, 2019, without admitting or denying the findings, BBTS consented to the entry of an Order (File No.
3-19068) by the United States Securities and Exchange Commission (“SEC”) Instituting Administrative Cease-
and-Desist Proceedings, Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist Order
(“Order”). The Order was issued pursuant to the SEC’s Share Class Selection Disclosure Initiative (“SCSD
Initiative”), a voluntary initiative where Firms self-reported conduct to the SEC. The Order is one of 79 Orders
issued pursuant to the SDSD Initiative on March 11, 2019. The Order states that from 2014 to 2016, BBTS
purchased, recommended, or held for advisory Client’s mutual fund share classes that charged 12b-1 fees instead
of lower-cost share classes of the same funds for which the Clients were eligible, and that BBTS and its associated
persons received 12b-1 fees in connection with these investments. The Order states that the Firm failed to disclose
the conflicts of interest related to its receipt of 12b-1 fees, and/or its selection of mutual fund share classes that
pay such fees. The Order further states that, as a result of the conduct described above, BBTS willfully violated
Sections 206(2) and 207 of the Advisers Act. The Order requires BBTS to complete certain undertakings, three of
which were completed prior to the Order being issued, censures BBTS, requires it to cease and desist from
committing or causing any violations of the above-referenced provisions, and to pay disgorgement of $336,875.69
and prejudgment interest of $39,183.54.
On August 14, 2024, the SEC announced the settled administrative order entered into by Truist Securities, Inc.,
Truist Investment Services, Inc. and Truist Advisory Services, Inc. (collectively, “Truist”) following the firm's Offer
of Settlement. The order was entered following Truist’s identification and self-disclosure of the unauthorized use
of off-channel communications to conduct SEC-regulated business. The order stated that certain employees of
Truist used off-channel communications against Truist policies. In addition, the order noted that Truist did not
maintain the off-channel communications or reasonably supervise employees in relation to off-channel
communications. Truist admitted the SEC's findings of fact, acknowledged that its conduct violated the federal
securities laws, agreed to retain a compliance consultant to review relevant policies and procedures, and agreed
to the making, keeping and preserving of certain required books and records. The order censured the firm,
required that the firm cease and desist from violating the federal securities laws cited in the order, and imposed a
civil money penalty in the amount of $5,500,000.
On August 14, 2024, Truist Bank consented to entry of a CFTC Order instituting administrative and cease-and-
desist proceedings and imposing remedial actions, following its identification and self-disclosure of substantially
similar conduct, Under the CFTC Order, Truist Bank paid a civil penalty of $3,000,000 on August 21, 2024, and
agreed to undertake a similar compliance review.
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Truist Investment Services, Inc. is registered as a broker-dealer under the Securities Exchange Act of 1934. The
principal business of TIS is that of a registered securities broker-dealer and certain TAS associates are dually
registered as registered representatives of the broker-dealer. The management personnel are all securities
registered primarily for oversight of the securities business. Generally, management personnel are not actively
selling investment products.
TIS is also an insurance agency and certain TAS associates are also insurance licensed and appointed through
the insurance agency. There are members of management who are insurance licensed and appointed through
TIS primarily for oversight of insurance business. Like brokerage, management personnel are generally not
actively selling insurance products.
TAS has the following agreements with TIS:
Dual Representative Agreement: Under this agreement, certain TAS Advisors are dually registered with TIS and
offer brokerage and insurance products and services to TAS Clients as well as offering TAS AMC Program and
services.
Research and Other Services Agreement: Under the agreement, TAS IAG generates reports of due diligence
conducted on investment vehicles, creates or negotiates third-party advertising, marketing and research materials,
design, monitor and update as needed on a continuous basis, capital market assumptions strategic, tactical, and
neutral allocations, watch list and ad-hoc manager and performance updates and consultative services.
Services Agreement: Under the agreement TIS provides TAS such items as best execution reporting,
maintenance of TAS’ books and records and AML processes related to Clients of the AMC Program. TAS, under
the agreement, provides payment of clearing and execution costs related to advisory account trades.
Truist Bank is state chartered bank and trust company authorized under the law of North Carolina to provided
banking and trust services. Certain Truist Bank employees are registered with TAS as investment adviser
representatives and offer the AMC Programs to their Clients.
TAS has the following agreements with Truist Bank:
Dual Representative Agreement: Under this agreement, certain TAS Advisors, Investment Managers, are
employed by Truist Bank and offer Truist Bank deposit and investment products and services to Truist Bank Clients
as well as offering TAS AMC Programs and services to Truist Bank Clients. This Agreement relates to each
organization’s supervisory responsibilities and requires that each organization clearly identify the products and
services which they separately provide to Clients.
Administration and Operational Services Agreement: Such items as business insurance, facilities
management allocation, audit/internal control and human resources allocations, among other items are provided
to TAS by Truist Bank and allocated by inter-company agreements.
Solicitation Agreement: Under the agreement, TAS can refer Clients to Truist Bank for investment advisory or
asset management services and receives compensation for such solicitations.
Non-Deposit Retail Sales (Networking) Agreement: Under the agreement, unregistered Truist Bank employees
can refer qualified bank Clients to TAS Advisors for a one-time nominal fee of a fixed dollar amount that is not
contingent on whether the qualified Client referral results in any advisory activity or the establishment of an
investment advisory relationship. In addition, this agreement allows unregistered bank employees to receive
contingent compensation for referrals of high-net worth individuals (prospects with investable assets greater than
$5,000,000) which will be received by the referring bank employee only of TAS investment advisory services are
purchased. TAS reimburses Truist Bank for all referral fees on a quarterly basis.
Model Manager Agreement: Under the agreement, TAS’ IAG constructs and maintains on a continuous basis
one or more model portfolios meeting the investment objectives outlined by TB for use in connection with its
investment management and trust accounts.
Research and Other Services Agreement: Under the agreement, TAS IAG generates reports of due diligence
conducted on investment vehicles, creates or negotiates third-party advertising, marketing and research materials,
design, monitor and update as needed on a continuous basis, capital market assumptions strategic, tactical, and
neutral allocations, watch list and ad-hoc manager and performance updates and consultative services. Under
this agreement TAS personnel also review financial planning presentations prepared by TB for TB customers.
TAS has the following agreements with GFO Advisory Services, LLC (“GFO”), an affiliate of TAS:
Services Agreement: Certain TAS personnel are also associated with GFO. TAS has entered into shared
services agreement with GFO which provides that certain services and costs associated with the use of TAS
personnel and services to GFO business functions shall be allocated to and charged to GFO pursuant to inter-
company agreement which provides for each entity to share in the costs associated with those employees and
the services they provide.
TFC - Sterling Capital Management LLC Referral Agreement
Under the terms of TFC’s agreements with Guardian Capital Group Limited (“Guardian”) relating to TFC’s sale of
Sterling to Guardian, TFC may receive additional financial benefits if Sterling’s investment advisory, separate
account management, unified managed account model portfolio services, and other advisory services are used
in connection with TAS Program Accounts (other than Retirement Accounts).
CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING
Code of Ethics
TAS has adopted a Code of Ethics (“Code”) for its advisory business which is intended to reinforce the fiduciary
principles that govern the conduct of the Firm and our personnel. This Code sets the standards of conduct
expected of our advisory personnel, safeguards to material nonpublic information about Client accounts and
transactions and requires certain personnel to report their personal securities transactions. A copy of the TAS
Code is available upon request from any TAS Advisor.
Participation in Client Transactions
TAS and our investment personnel can recommend securities in which we or our investment personnel or
employees have a financial interest or control relationship directly or indirectly, and we or our investment personnel
can buy and sell securities that we or they recommend to advisory Clients for purchase and sale. They can also
give advice and take action in the performance of their duties to Clients that differs from advice given, or the timing
and nature of action taken, with respect to other Clients’ accounts.
Personal Trading
Personal securities transactions by TAS employees or transactions for the Firm’s affiliates can raise conflicts of
interest when a security is traded that is 1) owned by Client or 2) considered for purchase or sale for Client. TAS
has, as part of its internal compliance program, adopted policies and procedures which impose certain rules and
restrictions as to transactions for the Firm's account and for the accounts of employees and affiliates. Such policies
and procedures are designed to prevent improper or unethical conduct whenever a conflict of interest can arise.
Personal trading by our employees must be conducted in compliance with all applicable laws and procedures.
See CONFLICTS OF INTEREST – Trading for Own and Other Accounts Section above for details.
Other Advice
TAS performs for other Clients, services similar to those that are provided to the Program Clients, as well as other
types of investment related services. TAS can take actions and give advice that can differ from the advice given,
or in the timing and nature of the action taken, with respect to the account of any Program Client. Neither TAS nor
anyone associated with TAS has any obligation to make or refrain from making to any Program Client
recommendations, purchases, sales, or transfers of any investment that can be purchased or sold for any other
Client or for the benefit of anyone associated with them. Transactions in any specific investment can be executed
at different times and prices for different Clients. TAS can utilize different schedules as they relate to fees for the
Programs; therefore, the costs of obtaining services similar to a Program can be more or less than those charged
to other Clients of TAS. See CONFLICTS OF INTEREST – Different Advice Section above for details.
Political Contributions
Truist Bank, its affiliates and their employees can make political and charitable contributions to various persons
and organizations, subject to the limits within the Firm’s political contribution policy. The ensuing goodwill can
result in added business to TAS. See CONFLICTS OF INTEREST – Political Contributions Section above for
details.
REVIEW OF ACCOUNTS
The TIS/TAS Product and Platform Committee and the TIS/TAS Policy Committee approve or reject new or
modified models across the Truist enterprise and services provided by IAG to affiliates.
TAS AMC Managed Programs
Supervisory reviews are conducted by the TAS’ Central Supervision Group (“CSG”), which consists of the Director
of Advisory Supervision and Regional Supervisors (“RS”).
The Director of Advisory Supervision and their RS Team are responsible for reviewing AMC Program account
opening documentation, trading within each account and the annual investment reviews of AMC Allocation Plus,
AMC Advise and AMC Annuity program accounts, among other items for their designated areas. The Firm utilizes
a surveillance program that the RS’ use to monitor the trading in Program accounts via alerts and filters on a
regular basis.
AMC Truist Invest Program
At least annually, based on the AMC Truist Invest Program account opening date, Clients will be notified by email
to review the investment profile information contained within their personal AMC Truist Invest online Client
Dashboard and reconfirm. The purpose of this review includes a determination as to whether any adjustment to
the Client’s investment strategy may be appropriate.
If Client does not respond to TAS’ review initiation within a specified time period, TAS will assume, based on the
principle of negative consent, that none of the Client’s information has changed, the Client does not wish to impose
or modify any permitted reasonable restrictions on their AMC Truist Invest Program account, and TAS should not
make any changes to its goal projections or investment decisions. However, if TAS considers this review to be
inadequate, to fail to comply with TAS’ requirements under the Advisers Act or other applicable laws, or otherwise
determine now or at any time that AMC Truist Invest Program is unsuitable for Client, TAS may terminate Client’s
AMC Truist Invest account.
AMC Truist Invest Program conducts annual reviews of advisory accounts to ensure they conform to TAS policies
and procedures. In addition, TAS reviews a percentage of advisory accounts on a random basis during the year
for such purpose.
TAS is responsible for periodically reviewing trading data and other automated reports and overseeing the trading
activity performed by NFS on behalf of Clients. The reviews include, without limitation, a verification that actual
trading activity is consistent with the risk categories, asset allocation targets for those categories and eligible
investment vehicles for each asset class TAS provides inputs for the Algorithm and the resulting investment
decisions, an analysis of risks associated with those investment decisions, and a determination that trading is
undertaken in compliance with applicable regulations. These reviews may result in changes to the capital markets
assumptions, risk categories, asset allocation targets for those categories and eligible investment vehicles for
each asset class and/or other aspects of the Program.
The TAS Digital Investing Group receives comprehensive monthly reports detailing each Client’s account
characteristics and periodically monitors target vs. current asset allocation, Client profile information, number of
trades, diversification and assets under management.
The online platform provides real-time performance information about Client’s Program account on the Client’s
Dashboard. As mentioned above, any updated financial information flows into the Algorithm and affects the
resulting goal projections and investment decisions associated with a Client’s account. If a Client decides that
AMC Truist Invest Program no longer fits their investing needs, the Client can terminate their AMC Truist Invest
Program account and the Client’s advisory relationship with TAS. If a Client does so, TAS will not have any
continued obligation to act or advise, as the case may be, with respect to the Client or their Brokerage Account
assets.
AMC Program Accounts
Clients receive written confirmations from NFS when a trade is executed in their account and can elect to receive
such confirmations electronically; however, Clients will have the option of waiving receipt of separate transactional
confirmations in exchange for a quarterly compilation of all transactions. Clients only receive monthly written
statements from NFS if there has been activity in their account otherwise the Client receives a quarterly brokerage
statement and can elect to receive such statements electronically. Such statements reflect the activity in the
account during the specific time period.
Clients can request quarterly investment performance reports (“Quarterly Report”) prepared by Envestnet which
reflect Client’s account investment performance vs. benchmark(s) at no additional cost. Clients should compare
their Quarterly Report information to their quarterly account statements from NFS and should report any
discrepancies to their TAS Advisor. Quarterly Reports are not available for Clients in the AMC Truist Invest
Program.
TAS conducts an annual mailing to Clients that includes a summary of the Client’s financial information, investment
objectives and current restrictions on their account, if any, advising the Client that their account will continue to be
managed according to those elements. Clients have the opportunity to contact their TAS Advisor to clarify or make
changes as necessary.
TAS also periodically offers Clients the opportunity to notify their Advisor of any changes to their financial and tax
situation, risk tolerance or financial goals. The Client, however, remains responsible for notifying TAS of any
material change in his or her investment profile. Updated information is submitted to the Platform Manager for
maintenance of Client data.
PAYMENT FOR CLIENT REFERRALS
When permitted under applicable incentive compensation agreements, unregistered Truist Bank employees are
paid a nominal referral fee for making general referrals of customers to TAS. In addition, this agreement allows
unregistered bank employees to receive contingent compensation for referrals of high-net-worth individuals
(prospects with investable assets greater than $5,000,000) which will be received by the referring bank employee
only of TAS investment advisory services are purchased. See Other Financial Industry Activities and
Affiliations, Truist Bank Non-Deposit Retail Sales (Networking) Agreement, above for details.
CAC Referrals
Securities registered TIS Financial Advisors (“FAs”) can refer Clients to the CAC and receive a $100 referral fee
from Truist Investment Services, Inc., the broker-dealer affiliate of TAS which provides account trading and
administration services to the TAS AMC Programs. Qualified referrals are based upon the opening of a new
account with a portfolio within the CAC between $50,000 and $100,000 of investible assets.
Referrals of Client Advisors and Premier Bankers
Truist Bank (“TB”) and TAS Client Advisors (“CAs”) and Premier Bankers (“PBs”) work together in teams that
include TAS Advisors to help determine potential solutions for each Client’s financial goals. Information gathered
and reports created are shared among the team members from both entities. Some CAs and PBs are also
registered investment adviser representatives of TAS. These bank advisors can refer Clients to TAS and can be
part of the overall Client team. See Conflicts of Interest - Premier Banker and Other Licensed Bank Employee
Referrals Section above.
Those CAs and PBs who are not registered with TAS are prohibited from referring Clients to TAS.
TAS Registered CAs and PBs are indirectly compensated for Client referrals to TAS by TB. Such compensation
is based on the asset under management amount (“AUM”) of Clients referred to TAS. When the totality of referred
Client’s AUM reaches certain levels specified in their applicable Financial Incentive Program, a CA’s or PB’s salary
will be adjusted and paid by TB. The receipt of incentive compensation in connection with recommendations to
invest in the AMC Programs creates a conflict of interest for the CAs and PBs and the Firm. See Conflicts of
Interest - Financial Incentive Programs section above.
Truist Wealth Management RESERVE
Truist Bank has partnered with third-party vendors to bring additional services to certain segments of its Clients,
including TAS Clients.
The additional services available to TAS Clients include:
• Access to jet-leasing services;
• Access to personal excess liability insurance for litigation protection;
• Access to healthcare advocacy and advisory support.
These are optional services that have additional fees to be paid to the third-party providers and are not included
in TAS Program Fee. TAS Program Fee is not affected by these services.
Truist Bank conducts initial and ongoing due diligence reviews on all vendors whose services are available to
TAS Clients related to this program. No compensation is received by Truist or any affiliate as a result of these
arrangements.
INDEX
Cover Page 1
Material Changes 2
Table of Contents 3
Services, Fees and Compensation 7
Account Requirements and Types of Clients 22
Portfolio Manager and Model Manager Selection and Evaluation 23
Conflicts of Interest 24
Advisory Services 33
Performance Fees and Side-By-Side Management (Not applicable to TAS, not included)
Methods of Analysis, Investment Strategies and Risk of Loss 46
Voting Client Securities 54
Client Information Provided to Portfolio Managers 55
Client Contact with Portfolio Managers 56
Additional Information 56
Disciplinary Information 56
Other Financial Industry Activities and Affiliations 58
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 59
Review of Accounts 60
Payment for Client Referrals 61
Financial Information (Not applicable to TAS, not included)
Index 63
