TBH Advisors, LLC (“TBH Advisors”, we, us, our, ours) is a Limited Liability
Company organized under the laws of the State of Tennessee. David Merrell, Sam
Davis, Phil Reynolds and Travis Anderson founded the Brentwood, TN-based
investment advisory firm in 2015. TBH Advisors is umbrella registered under TBH
Global Asset Management, LLC, a SEC registered investment adviser.
We offer investment advisory services which include the discretionary management
of investment portfolios in accordance with your investment objective(s). We may
also provide consulting services on investment-related matters. In addition, we may
offer these investment advisory services through TBH Advisors from our offices
located at 6 Cadillac Drive Suite 300, Brentwood, TN 37027 and 125 3rd Avenue
North, Franklin, TN 37064.
When we act as your investment adviser, we have to act in your best interest and not
put our interest ahead of yours. At the same time, the way we make money creates
some conflicts with your interests. You should understand and ask us about these
conflicts because they can affect the investment advice we provide you.
Investment Management Services
Through the use of discussions, interviews and/or client questionnaires, we assist
you in determining your investment goals and identifying your risk tolerance levels.
Once this process is complete, we will develop a customized portfolio for you
using a mix of domestic and foreign equities, fixed income securities, mutual funds
and exchange traded funds. F or o u r a cc re d i t ed in ve s to r s a nd t ho se wh os e
p o r tf ol io s a r e d e em e d a pp r op r ia te , We may also use alternative investments,
such as limited partnerships, private equity funds, and REITs that are not publicly
traded, on a limited basis. These types of investments contain considerable risk and
therefore are only recommended for portfolios that can withstand the possibility of
exposure to loss of principal.
Portfolios are diversified based upon your risk profile, investment horizon, financial
goals, income (current and potential), and other various suitability factors. We use
our discretionary authority to select individual securities with the aid of
fundamental analysis and the review of independent research, news sources and
rating services. We generally manage portfolios directly, although we may engage
third party asset managers to meet specific needs.
5 | P a g e In managing your investment portfolio, we consider your financial situation, risk
tolerance, investment horizon, liquidity needs, tax considerations, investment
objectives and any other issues important to your state of affairs. You should notify
us promptly if there are any changes in your financial situation or investment
objectives or if you wish to impose any reasonable restrictions upon the management
of your account.
Financial Planning
We also offer financial planning services. We meet with you to gather information
about your current financial position including securities and business holdings,
insurance policies, real estate, other investments and potential inheritance. In
addition, we will gather income and gift tax returns as well as estate planning
documents. We will evaluate your current position and make recommendations on
how you can achieve your business, estate and retirement goals. We will provide a
report after all information is received by the client. Clients who receive separate
financial planning services, although we generally recommend our investment
management services, are under no obligation to utilize our firm for investment
management.
For some individuals who are utilizing financial planning as part of their investment
management services, we may waive the fee for the financial planning.
We do not make recommendations on specific securities but will recommend types
of investments within specific asset classes. We will meet with you as often
as requested, but no less than annually during the engagement period. We do
not provide legal or tax advice and you should consult your attorney or tax adviser
for these types of questions or guidance.
Consulting Services
We may provide separate consulting services as contracted by the client. These
services will be directed by the client’s specific needs and are provided on a one-
time basis. As such, the client agreement will outline the services to be provided and
most services are based upon an estimated hourly rate, as described in Item 5 of this
brochure.
6 | P a g e Retirement and Pension (RP) Planning Services Plan Consulting
TBH works with the Third-Party Administrator and the Retirement Plan (RP) to
review the investment options available to the RP. TBH will make recommendations
to assist the RP in selecting investments. Once the RP’s investments are selected, the
TPA will execute any transactions and clear the accounts. TBH, on a periodic basis,
will review reports and information generated from the TPA to assist the RP
Sponsor/Trustee in monitoring and evaluating the RP’s investment alternatives.
Participants of Plans
TBH may also provide investment advice directly to plan participants but only as a
non-discretionary fiduciary. TBH provides participants with diversification strategies
and recommendations, and the participants will have the sole responsibility to execute
the transactions. In some cases, TBH may, after approval of the Client, instruct the
record-keeper or third-party administrator to execute recommendations on the
Client’s behalf.
From time to time, TBH will also meet with plan participants to provide general
investment education, which may include basic information regarding insurance
products, mutual funds, annuities, inflation, risk and diversification.
Assets Under Management
As of December 31, 2019, we managed approximately $ 72,676,631 in client assets
on a discretionary basis where we made all of the investment decisions. Our
advisor does not provide non-discretionary advice at this time.
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Fees for Investment Management Services
We offer our services on a fee-only basis. Our investment management fees will
be paid quarterly in advance based on ending prior quarter market valuations.
Primarily, clients will sign a written authorization to have fees directly debited from
their accounts held at the qualified custodian. Your custodian does not determine
the fee for billing as TBH Advisors will send the bill to the custodian for fee
payments. Clients should review their quarterly statements and notify our firm of
any inconsistencies. Rarely, we will, at the client’s request, directly bill the client for
services rendered. These clients will receive an invoice for the quarter.
7 | P a g e Fees for the initial quarter are based on the value of your cash and securities on the
date the custodian receives them and are prorated based upon the number of
calendar days in the calendar quarter that our agreement is in effect.
Our fee schedule is described below:
Assets under Management Advisory Fee First $500,000 2.00%
Next $1,500,000 (up to $2,000,000) 1.75%
Next $3,000,000 (up to $5,000,000) 1.50%
Above $5 million 1.20%
All fees are negotiable at our sole discretion. We may group some client accounts
together to meet minimum thresholds. In addition, we have grand-fathered some
client’s fees that were established accounts prior to changes, acquisitions and mergers.
Finally, for certain family and friends, at our sole discretion, we may waive fees in part
or in entirety.
Fees for Financial Planning
We offer our financial planning services for either an hourly or fixed fee; or, as
a percent of gross income.
Financial Planning Fees
Percent of Income Maximum 1%
Fixed fees are separately negotiated with each client and agreed to in a written
agreement. The fees are based upon the complexity of assets, number of areas
analyzed, depth of analysis required, or other unique reasons agreed upon by you
and us. An estimate of the time involved will be provided before signing the advisory
agreement. All fees are negotiable at our discretion.
Fixed fees are billed 50% as an upfront retainer and the remainder is due upon
completion of the project. Fees assessed as a percent of income are billed semi-
annually, with the first installment payable when the advisory agreement is executed.
Billing will continue until the agreement is terminated. No fees will ever be charged
six months or more in advance for work performed. Clients who have paid fees in
advance will receive a refund pro-rated for work performed.
If you choose to implement your financial plan through our IAR in this capacity, he
may receive commissions or other compensation such as mutual fund 12b-1 fees as
a result of those securities transactions. This may create a conflict of interest for the
IAR as he may recommend products based on the compensation he may receive.
8 | P a g e Fees for Consulting Services Hourly fees are separately negotiated with the client and based upon the complexity
of the plan. The fees will be agreed to in writing prior to commencement of the
work. Hourly consulting services are billed and paid on a monthly basis as services
are provided.
Fees for Retirement Plan Services
In connection with its consulting services, TBH charges annual asset-based fees that
are negotiated separately with each client. Negotiated fees are generally based on the
value of the plan’s assets and the complexity of the plan. In lieu of asset-based fees,
we may agree to a flat dollar fee structure for consulting services, when specifically
requested by the TPA or RP and as directed in plan documents.
As previously noted, fees are negotiated based on the size and complexity of the
plan, among other things. These fees are either directly debited from the Client’s
account by the record-keeper, TPA, or custodian or billed directly to the Client, and
are payable in advance or in arrears, as separately negotiated with each client.
Your Third-Party Administrator (“TPA”) sends a statement that includes the value
of your investments, our advisory fee, and how it is calculated. Your custodian
also provides you with statements that show the amount paid directly to us. You
should compare the statement the TPA sends to your custodian’s statement and
verify the calculation of our fees. Your custodian does not verify the accuracy of
fee calculations.
General Information about Our Fees
In addition to our fee, clients are subject to fees and transaction costs from the
separate broker/dealers and custodians working with your account. In addition,
Sponsors may have additional fees for management of your account, maintenance
and administration. These fees are separate and customary from the fee we charge
you for advisory services.
Mutual fund companies, ETFs, and variable annuity issuers charge internal fees and
expenses for their products. These fees and expenses are in addition to any advisory
fees charged by us. Complete details of these internal fees and expenses are
explained in the prospectuses for each investment. You are strongly encouraged to
read these explanations before investing any money. You may ask us any questions
you have about fees and expenses.
If you purchase mutual funds through the custodian, you may pay a transaction
fee that would not be charged if the transactions were made directly through the
9 | P a g e mutual fund company. Also, mutual funds held in accounts at brokerage firms
may pay internal fees that are different from funds held at the mutual fund company.
While you may purchase shares of mutual funds directly from the mutual fund
company without a transaction fee, those investments would not be part of our
advisory relationship with you. This means that they would not be included in our
investment strategies, investment performance monitoring, or portfolio
reallocations.
Certain members of our firm are also registered as registered representatives and/or
insurance agents. As such, these individuals will receive commissions based on the
sale of securities or insurance products. The fees clients pay for the purchase of these
products benefit TBH Advisors registered personnel and are separate from the
advisory service fees paid for advisory services. This represents a conflict of interest.
We mitigate this conflict by disclosing it to our clients. Clients are under no
obligation to purchase securities or insurance products from individuals associated
with our firm.
Please be sure to read the section entitled “Brokerage Practices,” which follows
later in this brochure.
Our advisory representatives may also recommend various asset management
firms. If you establish an investment advisory relationship with one of these
firms, our financial advisors may share in the advisory fees you pay to these asset
management firms.
Termination of Advisory Agreement
You must pay our advisory fees in advance of receiving our services. You may
terminate the advisory agreement within five (5) business days from the date the
agreement is executed without penalty and will receive a full refund of any fees paid.
Other than initial execution of this Agreement, this agreement may be terminated at
any time by either party hereto giving written notice to the other, and such termination
shall become effective as of delivery of the notice of such termination. Fees paid in
advance will be prorated to the date of termination specified in the notice of
termination and any unearned portion thereof will be refunded to Client. If you pay
in arrears, any outstanding fees will be due immediately upon termination. If you are
billed in advance, any prepaid fees will be returned on a pro-rata basis.
Should either one of us terminate the advisory agreement before the end of a billing
period, any unearned fees that were deducted from your account will be typically
returned to you by us. The amount refunded to you is calculated by dividing the
most recent advisory fee you paid by the total number of days in the quarter.
10 | P a g e This daily fee is then multiplied by the number of calendar days in the quarter that
our agreement was in effect. This amount, which equals the amount we earned
for the partial quarter, is subtracted from the total fee you paid in advance to
determine your refund.
The fixed fee for financial planning services is billed 50% upon engagement. You
have the right to terminate any advisory contract within five (5) business days after
executing the agreement. After that time, our services may be terminated at any time
upon written notice and payment in full of all fees and expenses we have earned at
the time of termination. Any unearned fees will be refunded. The amount of the
refund will be the difference between the deposit amount and the hourly rate of $175
times the number of hours spent to date on the planning project.
Registered Representative of an Unaffiliated Brokerage and Insurance Agents Compensation for Sales of Securities Broker-Dealer Affiliation - Certain advisory persons are also registered
representatives of Independence Capital Co., Inc, (‘ICC”) an unaffiliated, registered
broker-dealer (CRD# 24723), member FINRA, SIPC. In the individual’s capacity as
a registered representative of ICC, he/she will implement securities transactions
under ICC and not through TBH Advisors. In such instances, the registered
representative will receive commission-based compensation in connection with the
purchase and sale of securities, including 12b-1 fees for the sale of investment
company products. Compensation earned by an advisory person in the capacity as a
registered representative is separate and in addition to the Advisor’s fees. This
practice presents a conflict of interest because advisory persons who are registered
representatives have an incentive to effect securities transactions for the purpose of
generating commissions. Clients are not obligated to implement any
recommendation provided by the advisory person(s)whether acting in the capacity of
a registered representative or in the capacity of an advisory person. TBH Advisors
nor advisory persons associated with the broker/dealer will earn investment advisory
fees in connection with any products or services implemented in the advisory
person’s separate capacity as a registered representative. Please see Item 10.
Insurance Agency Affiliations - Certain advisory persons are also licensed as
independent insurance professionals. As an independent insurance professional, an
advisory person may earn commission-based compensation for selling insurance
products, including insurance products they sell to clients. Insurance commissions
earned by an advisory person. Are separate and in addition to TBH Advisor’s
advisory fees. This practice presents a conflict of interest because a person providing
investment advice on behalf of the Advisor who is also an insurance agent has an
incentive to recommend insurance products to Clients for the purpose of generating
commissions rather than solely based on Client needs. However, Clients are under
11 | P a g e no obligation, contractually or otherwise, to purchase insurance products through an
advisory person of TBH Advisors.
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Performance-based fees are based on a percentage of the capital gains on or
appreciation of the client account assets. We do not charge performance-based
fees on any of our client accounts.
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We provide advisory services primarily to individuals and high net worth individuals,
including their trusts, estates and retirement accounts. We also provide services
to corporations or business entities including their pension and profit-sharing plans.
We currently have no stated minimum account size and no minimum fee
requirements.
Item – 8 Methods of Analysis, Investment Strategies and Risk of
Loss
We select specific investments for your portfolios through the use of fundamental
analysis.
Fundamental analysis is a method of evaluating a company that has issued a security
by attempting to measure the value of its underlying assets. It entails studying overall
economic and industry conditions as well as the financial condition and the quality
of the company’s management. Earnings, expenses, assets, and liabilities are all
important in determining the value of a company. The value is then compared to
the current price of the issuing company’s security to determine whether to purchase,
sell or hold the security.
Our investment strategies may include long-term and short-term purchases and sales.
Although we manage your account in a manner, we believe is consistent with your
specific investment objectives and risk tolerances, there can be no guarantee that our
efforts will be successful. General economic conditions, current interest rates, the
performance of a particular industry or a particular company, and any number
of other factors can affect investment performance.
12 | P a g e Third Party Manager Analysis As previously noted, we may recommend the use of third-party investment
managers to implement our investment advice. We analyze individual investment
managers based upon their investment strategies, experience, performance track
record, reputations, and fee arrangements. A risk with this type of strategy is that
the money manager may not perform as was expected from the analysis we
performed.
Investment Risk All investments contain risk. You should be prepared to bear the risk of loss. All investments are
subject to loss, including (among other things) loss of principal, a reduction in earnings (including
interest, dividends and other distributions), and the loss of future earnings.
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We have not been the subject of any legal or disciplinary events that would
be material to your evaluation of our business or the integrity of our management.
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Certain owners and officers of TBH Advisors are also owners and/or officers of
TBH Global Asset Management, LLC (“TBH Global”). TBH Global is an SEC-
registered investment adviser, which umbrellas its registration with the SEC due to its
affiliation with TBH Advisors. Certain Officers, Directors and Investment
Advisor Representatives are also Officers, Directors and Investment Advisor
Representatives of TBH Global. These individuals may recommend the services of
TBH Global for certain clients who also utilize our firm. This represents a conflict
of interest as these individuals will benefit by the recommendation. As such, they
receive separate, yet customary compensation for these advisory services or
compensation based on ownership. The separate fees and compensation are
disclosed in the TBH Global Form ADV Part 2A Firm Disclosure Brochure. We
mitigate this conflict by disclosing it to you, our client. Clients are under no
obligation to utilize the services of TBH Advisors, when we recommend such
services.
An officer of TBH Advisors is appointed as a Director for SCC Bancshares, Inc. which
is a holding company for St. Clair County State Bank in Missouri. TBH Global and
TBH Advisors and their respective officers and owners do not recommend this bank
or any of its affiliates to clients or prospective clients. Our firm mitigates potential
conflicts by disclosing this ownership to clients and potential clients.
13 | P a g e Registered Representatives of an Unaffiliated Brokerage and Insurance Agents Compensation for Sales of Securities Broker-Dealer Affiliation Certain advisory
persons are also registered representatives of Independence Capital Co., Inc, (‘ICC”)
an unaffiliated, registered broker-dealer (CRD# 24723), member FINRA, SIPC. In
the individual’s capacity as a registered representative of ICC, he/she may implement
securities transactions under ICC and not through TBH Advisors. In such instances,
the registered representative will receive commission-based compensation in
connection with the purchase and sale of securities, including 12b-1 fees for the sale
of investment company products. Compensation earned by an advisory person in
one’s capacity as a registered representative is separate and in addition to the
Advisor’s fees. This practice presents a conflict of interest because advisory persons
who are registered representatives have an incentive to effect securities transactions
for the purpose of generating commissions. Clients are under no obligation to
implement any recommendation provided by the advisory person(s). Neither the
Advisor nor advisory persons will earn ongoing investment advisory fees in
connection with any products or services implemented in the advisory person’s
separate capacity as a registered representative.
Insurance Agency Affiliations Certain advisory persons are also licensed as
independent insurance professionals. As an independent insurance professional, an
advisory person may earn commission-based compensation for selling insurance
products, including insurance products they sell to clients. Insurance commissions
earned by an advisory person. Are separate and in addition to TBH Advisor’s
advisory fees. This practice presents a conflict of interest because a person providing
investment advice on behalf of the Advisor who is also an insurance agent has an
incentive to recommend insurance products to Clients for the purpose of generating
commissions rather than solely based on Client needs. However, Clients are under
no obligation, contractually or otherwise, to purchase insurance products through an
advisory person of TBH Advisors.
Information about your IAR’s financial industry activities and affiliations is
disclosed in the IAR’s Supplement which you will receive with this brochure.
Additional information about your IAR is also available a
t www.adviserinfo.sec.gov. 14 | P a g e
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Transactions and Personal Trading
We have adopted a
Code of Ethics (“
Code”) to address the securities-related conduct
of our advisory representatives and employees. The
Code includes our policies and
procedures developed to protect your interests in relation to the following:
• the duty at all times to place your interests ahead of ours;
• that all personal securities transactions of our advisory representatives and
employees be conducted in a manner consistent with the
Code and avoid any actual
or potential conflict of interest, or any abuse of an advisory representative’s or
employee’s position of trust and responsibility;
• that advisory representatives may not take inappropriate advantage of their
positions
• that information concerning the identity of your security holdings and financial
circumstances are confidential; and
• that independence in the investment decision-making process is paramount.
We will provide a copy of the
Code to you or any prospective client
upon request.
We do not buy or sell securities for our firm that we also recommend to clients. Our
advisory representatives and employees are permitted to buy or sell the same
securities for their personal and family accounts that are bought or sold for your
account(s). The personal securities transactions by advisory representatives and
employees may raise potential conflicts of interest when they trade in a security that
is owned by you or considered for purchase or sale for you.
We have adopted policies and procedures that are intended address these conflicts
of interest. These policies and procedures:
• require our advisory representatives and employees to act in your best interest,
• prohibit favoring one client over another, and
• provide for the review of transactions to discover and correct any same-day
trades that result in an advisory representative or employee receiving a better price
than a client.
Transactions for the accounts of our employees and advisory representatives may
be included in aggregated trades. They receive the same average price and pay the
same commissions and other transaction costs, as clients. Transactions for the
accounts of our advisory representatives or employees will not be favored over
transactions for client accounts.
15 | P a g e It is TBH Advisor’s policy that the Advisor will not affect any principal or agency
cross securities transactions for Client accounts. The Advisor will also not cross
trades between Client accounts.
Advisory representatives and employees must follow our procedures when
purchasing or selling the same securities purchased or sold for you.
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Our firm does not hold clients’ assets. Clients are required to engage an independent,
non-affiliated, third-party qualified custodian. TBH Advisors will generally
recommend National Financial Services, (“NFS”) a FINRA Member broker-dealer,
CRD #13041, for their broker-dealer/qualified custodian. To a more limited extent,
we have recommended Raymond James, CRD #6694, another unaffiliated broker-
dealer/custodian to our clients. Although we recommend that clients establish
accounts at the referenced qualified custodian, it is the client's decision to custody
assets with NFS, Raymond James, or any other custodian of their choosing.
TBH Advisors is independently owned and operated and not affiliated with NFS or
Raymond James. When we recommend these broker-dealer/custodians, we believe in
the reasonableness of commissions based on the broker's stability, reputation, ability
to provide professional services, competitive commission rates and prices, research,
trading platform, and other services which will help TBH Advisors in providing
investment management services to clients. As such, our firm will receive use of a
trading platform and other operational assistance, including common research. When
we recommend NFS or Raymond James, clients may not receive the lowest
commission or execution price. Other broker/dealers may provide securities
transaction services with lower prices.
Research services may be useful in servicing all our clients, and not all of such
research may be useful for the account for which the particular transaction was
effected. Our firm does not accept any soft dollar compensation arrangements. For
the client accounts that our firm provides advisory services, NFS or Raymond James
generally does not charge separately for custody services but is compensated by
charging commissions or other fees on trades that it executes or that settle into the
client’s account. We remind the client to carefully examine the broker-
dealer/custodian’s brokerage disclosures, received when opening an account, for an
understanding of all fees charge by NFS or Raymond James.
16 | P a g e We are not required to effect a minimum volume of transactions or maintain a
minimum dollar amount of client assets to receive these services.
Because the amount of our compensation or the products or services we receive may
vary depending on the custodian we recommend to be used by our clients, we may
have a conflict of interest in making that recommendation. Our recommendation
of specific custodians may be based in part on the economic benefit to us and not
solely on the nature, cost or quality of custody and brokerage services provided to
you and our other clients. We nonetheless strive to act in your best interests at all
times.
Commissions and other fees for transactions executed through Custodians we have
agreements with may be higher than commissions and other fees available if you use
another custodian firm to execute transactions and maintain custody of your
account. We believe, however, that the overall level of services and support
provided to our clients by Custodians outweighs the benefit of possibly lower
transaction costs which may be available under other brokerage arrangements.
Directed Brokerage
Our firm does not generally accept directed brokerage outside of the Custodians
that we recommend to our clients. TBH reserves the right to accept instructions
from clients to use a particular broker-dealer to execute some or all of the
transactions for t h e c l i e n t ’ s account. If a client elects to utilize a directed
brokerage arrangement outside of our recommended custodians, clients should be
aware that the client is solely responsible for negotiating the terms and
arrangements for the account with that broker-dealer.
We may not be able to negotiate commissions, obtain volume discounts, or best
execution. In addition, under these circumstances a difference in commission
charges may exist between the commissions charged to clients who direct us to
use a particular broker or dealer and other clients who do not direct us to use a
particular broker or dealer. Finally, our firm will execute these trades separately and
not aggregate or “bunch” a trade with our recommended Custodians trades.
17 | P a g e Aggregated Transactions We may engage in aggregated trading, which is the purchase or sale of a security for
the accounts of multiple clients in a single Custodian transaction. If an aggregated
trade is executed, each participating client receives a price that represents the average
of the prices at which all of the transactions in a given bunch were executed.
Accounts that participate in the same aggregated trade will be charged commissions,
if applicable, in accordance with their separate brokerage agreements. Different
accounts participating in an aggregated transaction may not be charged the same
commission rates, based on their brokerage agreements. If the order is not
completely filled, the securities purchased or sold are distributed among participating
clients on a pro rata basis or in some other equitable manner.
Aggregated trades are placed only when we reasonably believe that the combination
of the transactions provides better prices for clients than had individual
transactions been placed for clients.
We are not obligated to include any client account in an aggregated trade. Aggregated
trades will not be effected for any client’s account if doing so is prohibited
or otherwise inconsistent with that client’s investment advisory agreement. At
our sole discretion, non-discretionary accounts may not be included in aggregated
transactions.
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All client accounts are monitored on an ongoing basis with a formal review
conducted at least annually or as agreed upon with individual clients. The reviews
focus on the consistency of portfolio investments with each client’s stated
objectives and risk tolerances. Reviews also consider investment restrictions
requested by individual clients, investment time horizons, liquidity needs, tax
considerations and other circumstances unique to each client.
On a quarterly basis, the performance of your account is reviewed to monitor
consistency with market benchmarks that we deem applicable. Thereafter, your
account is reviewed on a transaction, monthly, quarterly or annual basis, as needed.
Account reviews may also be triggered by other factors such as changes in general
economic and market conditions, analyst reports, issuer news and interest rate
movement. Your advisory representative is responsible for all reviews.
18 | P a g e You will receive statements from the custodian at least quarterly. These statements
identify your current investment holdings, the cost of each of those investments, and
their current market values. If separately contracted by the client, clients will
receive performance analysis reports prepared by us which describe the returns
realized on the investments in your account.
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We may enter into written compensation agreements with certain unaffiliated
investment adviser representatives and professionals such as CPAs, attorneys, etc.
We would pay these persons a percentage of the fee that you pay to us if it is
determined you have become a client as a result of their direct or indirect efforts.
These payments are a portion of the fee that we charge and do not result in an
increase in the amount of the fee that you pay. Any solicitation or referral
arrangements will comply with applicable laws that govern:
• the nature of the service,
• fees to be paid,
• disclosures to clients, and
• any necessary client consents.
Investment Advisor Representatives affiliated with broker/dealers or insurance
companies are provided opportunities to receive bonuses, prizes or awards for these
separate sales activities. As such, this presents a conflict of interest that clients should
be aware of. We mitigate this conflict by disclosing it to our clients.
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TBH Advisors requires that all clients maintain their assets with a qualified custodian.
We previously disclosed in the "Fees and Compensation" section (Item 5) of this
Disclosure Brochure that our firm directly debits advisory fees from client accounts.
As part of this billing process, the client's custodian is advised of the amount of the
fee to be deducted from that client's account. On at least a quarterly basis, the
custodian is required to send to the client a statement showing all transactions within
the account during the reporting period. Because the custodian does not calculate the
amount of the fee to be deducted, it is important for clients to carefully review their
custodial statements to verify the accuracy of the calculation, among other things.
Clients should contact us directly, or the qualified custodian holding their assets, if
they believe that there may be an error in their statement.
19 | P a g e We also encourage you to contact your advisory representative or our Chief
Compliance Officer should you have any questions or concerns regarding your
account.
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We offer our advisory services on a discretionary basis. This means that we do not
need advance approval from you to determine the type and amount of securities to
be bought and sold for your accounts. We do not, however, have the ability to
choose the broker-dealer through which transactions will be executed. Additionally,
we do not have the ability to withdraw funds from your account (other than to
withdraw our advisory fees which, may only be done with your prior written
authorization.)
This discretion is used in a manner consistent with the stated investment
objectives for your account, if you have given us written authorization to do
so. We only exercise discretion in accounts where we have been authorized by you.
This authorization is typically included in the investment advisory agreement you
enter into with us.
Occasionally, we also manage accounts on a non-discretionary basis, which means we
must obtain your approval before for each transaction. In the event of a market
correction, if we cannot contact you to obtain consent, we would be unable to
effect any recommended action.
Typically, under third-party investment management arrangements, the third-party
investment manager exercises discretion in the management of your account. All
securities transactions are selected and executed by that manager. We do not manage
or obtain discretionary authority over the assets in those accounts.
You may, however, grant us the discretionary authority to hire and fire such
third-party managers on your behalf.
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We do not take any action or give any advice with respect to voting of proxies
solicited by or with respect to the issuers of securities in which your accounts may
be invested. In addition, we do not take any action or give any advice with respect
to any securities held in any accounts that are named in or subject to class action
lawsuits. We will, however, forward to you any information received by us
regarding proxies and class action legal matters involving any securities held in your
accounts.
20 | P a g e
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We have no financial commitment that impairs our ability to meet contractual and
fiduciary commitments to you and we have not been the subject of a bankruptcy
proceeding. TBH does not collects fees of $1,200 or more for services to be
performed six months or more in advance.
21 | P a g e Brochure Supplement
David J. Singer
125 3rd Avenue North
Franklin, Tennessee 37064
615-538-7018
TBH Advisors, LLC
6 Cadillac Dr.
Suite 300
Brentwood, TN 37027
615-690-4820
www.tbhadvisors.com
March 27, 2019This brochure supplement provides information about David J. Singer that supplements the TBH Advisors, LLC brochure. You should have received a copy of that brochure. Please contact Nicholas Warf, Chief Compliance Officer, if you did not receive TBH Advisors, LLC’s brochure or if you have any questions about the contents of this supplement.
Additional information about David J. Singer, CRD Number 5648414, is available on the SEC’s website at www.adviserinfo.sec.gov.22 | P a g e David J. Singer
Year of birth: 1983
Formal education:
• University of Dayton - 2008, Bachelor of General Studies
Business background:
• TBH Advisors, LLC – Advisory Representative,
(07/2016 – Present)
• Wells Fargo Advisors LLC – Registered Representative
(02/2012 – 06/2016)
• Wells Fargo Advisors Financial Network LLC, Registered
Representative (10/2011 – 01/2012)
• Thrivent Investment Management, Inc., Registered Representative
(02/2009-06/2011)
• Thrivent Financial For Lutherans. Financial Representative
(03/2009- 06/2010)
Disciplinary Information
Mr. Singer has not been the subject of any legal or disciplinary event.
Other Business Activities
Mr. Singer does not engage in any business activities other than those related to
TBH Advisors, LLC.
Additional Compensation
Mr. Singer does not receive any additional compensation related to the
advisory services provided to you.
23 | P a g e Supervision
Mr. Singer is supervised by David Merrell, Managing Partner. Mr. Merrell can be
reached at 615-690-4820.
We supervise Mr. Singer by requiring that he adhere to our processes and
procedures as described in our firm’s Code of Ethics. We will monitor the advice
that Mr. Singer gives to you by performing periodic, yet routine supervisory
reviews.
24 | P a g e Brochure Supplement Jeffrey L. Littrell
2615 Medical Center Drive Suite 1560 Murfreesboro, Tennessee 37129
615-460-4820
TBH Advisors, LLC
6 Cadillac Dr.
Suite 300
Brentwood, TN 37027
615-690-4820
www.tbhadvisors.com March 2, 2020
This brochure supplement provides information about Jeffrey L. Littrell that supplements the TBH Advisors, LLC brochure. You should have received a copy of that brochure. Please contact Nicholas Warf, Chief Compliance Officer, if you did not receive TBH Advisors, LLC’s brochure or if you have any questions about the contents of this supplement.
Additional information about Jeffrey L. Littrell, CRD Number 6124531, is available on the SEC’s website at www.adviserinfo.sec.gov.25 | P a g e Jeffrey L. Littrell
Year of birth: 1956
Formal education:
• Middle Tennessee State University
- 1978, Bachelor of Science
• Vanderbilt University – 1984, Masters of Divinity
Business background:
• TBH Advisors, LLC – Advisory Representative, (04/2018 – Present)
• Independence Capital Co., Inc. – Registered Representative, (9/7/2018 –
Present)
• Wells Fargo Advisors LLC – Registered Representative
(07/2014 – 04/2018)
• Edward Jones - Registered Representative (10/2012 – 07/2014)
Disciplinary Information
Mr. Littrell has not been the subject of any legal or disciplinary event.
Other Business Activities
In addition to his association with TBH Advisors, Mr. Littrell is a registered
representative of Independence Capital Company (“ICC”), a registered
broker/dealer and member FINRA/SIPC. Investment advice is offered
through TBH Advisors, a Registered Investment Adviser and separate entity
from ICC. He is also a licensed insurance agent offering insurance
products and services through unaffiliated insurance companies.
If Mr. Littrell performs services for you as a registered representative of a broker-
dealer or as an insurance agent, Mr. Littrell may receive commissions or other
compensation from the sale of securities and insurance products and services to
you. For example, Mr. Littrell may receive 12b-1 fees, which are fees paid by
mutual fund companies for the on-going marketing of their investment products.
26 | P a g e This additional compensation may present a conflict of interest because it creates
an incentive to recommend products and services based upon compensation,
rather than on your needs. Mr. Littrell will explain the costs associated with any
recommendations he makes. You have no obligation to do business with Mr.
Littrell in his other capacities.
Additional Compensation
Mr. Littrell receives additional compensation for his activities as a registered
representative of a broker-dealer and as an insurance agent. This may also
include applicable sales awards and other prizes. This compensation is described
under “Other Business Activities” above.
Supervision
Mr. Littrell is supervised by David Merrell, Managing Partner. Mr. Merrell can be
reached at 615-690-4820.
We supervise Mr. Littrell by requiring that he adhere to our processes and
procedures as described in our firm’s Code of Ethics. We will monitor the advice
that Mr. Littrell gives to you by performing periodic, yet routine supervisory
reviews.
27 | P a g e Brochure Supplement
William L. Butler
125 3rd Avenue North Franklin, Tennessee 37064
615-538-7018
TBH Advisors, LLC
6 Cadillac Dr.
Suite 300
Brentwood, TN 37027
615-690-4820
www.tbhadvisors.com March 27, 2019
This brochure supplement provides information about William L Butler that supplements the TBH Advisors, LLC brochure. You should have received a copy of that brochure. Please contact Nicholas, Chief Compliance Officer, if you did not receive TBH Advisors, LLC’s brochure or if you have any questions about the contents of this supplement.
Additional information about William L. Butler, CRD Number 5819916, is available on the SEC’s website at www.adviserinfo.sec.gov. 28 | P a g e William L. Butler
Year of birth: 1987
Formal education: University of Auburn - 2010, Bachelor of General Studies
Business background:
• TBH Advisors, LLC – Advisory Representative, (05/2018 – Present)
• Morgan Stanley Private Bank, National Association – Registered
Representative (07/2015 – 05/2018)
• Morgan Stanley Smith Barney - Registered Representative
(07/2010 – 05/2018)
Disciplinary Information:
Mr. Butler has not been the subject of any legal or disciplinary event.
Other Business Activities:
1. KPMCS, LLC. Ownership in restaurant Burger Up in Cool Springs- 401B Cool
Springs Blvd, Suite 200 Franklin, TN 37067- preferred member, provided initial
capital to start the restaurant. 3.5% financial and governing rights. No
management duties- 3.5% ownership-1 hour outside business hours, 0 during
trading hours- investment related.
2. Five Daughters bakery LLC, investor; investment related; start date: 07/2015;
during business hours -1, after business hours -1; Nashville, TN
3. Taco Lime, LLC DBA Mojo's Tacos; Not Investment; Food Restaurant; Sole
Proprietor / Owner / Partner (proprietor, partner, officer, director, employee,
trustee, agent); Nov 2017; During business hours: 0; After business hours: 2; One
of the partners providing capital to open the restaurant.
4. ADH Partnership - 1 hr/week, 10% Ownership
5. Hickman Properties – 1 hr/week – 100% Ownership
6. BDP, LLC – 1 hr/week - 22% Ownership
7. AB Family LP. 1hr/week – 75% Ownership
29 | P a g e Additional Compensation:
Mr. Butler does not receive any additional compensation related to the
advisory services provided to you.
Supervision:
Mr. Butler is supervised by David Merrell, Managing Partner. Mr. Merrell can be
reached at 615-690-4820.
We supervise Mr. Butler by requiring that he adhere to our processes and
procedures as described in our firm’s Code of Ethics. We will monitor the advice
that Mr. Butler gives to you by performing periodic, yet routine supervisory
reviews.
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Open Brochure from SEC website