Part 2A of Form ADV
Firm Brochure
January 2, 2020
TruVine Financial, LLC
17 Apple Orchard Road
Moorestown, NJ 08057
WWW.TruVineFinancial@gmail.com
215-858-8448
This Brochure provides information about the qualifications and business practices of TruVine Financial, LLC (“TruVine”). If you have any questions about the contents of this brochure, please contact us at 215-858-8448 or e-mail us at TSpuler@TruVineFinancial.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority.
TruVine is a registered investment advisor in the states of New Jersey and Pennsylvania. Registration of an investment advisor does not imply any level of skill or training. The oral and / or written communications of an Advisor provides you with information you can use in deciding whether to hire or retain an Advisor.
Additional information about TruVine Financial, LLC is available on the SEC’s website at www.adviserinfo.sec.gov.
Item 2 – Material Changes
On July 28, 2010, the United States Securities and Exchange Commission amended Part 2 of Form ADV. This Part 2 of Form ADV sets forth the minimum requirements for the disclosure statement that investment advisors must deliver to their advisory clients and prospective advisory clients.
Investment advisors must update the information in their brochure at least annually. In lieu of providing clients with a new brochure each year, we will provide existing advisory clients with this item 2 summary describing any material changes occurring since the last annual update of the brochure. We will deliver a brochure or summary each year to existing clients within 120 days of the close of our fiscal year.
There have been no material changes during the previous year.
Our current brochure is always available on our website at www.truvinefinancial.com. Clients wishing to receive a complete and updated brochure may request one at no charge by contacting us at 215-858-8448 or by emailing us at www.truvinefinancial.com
Additional information about TruVineFinancial is also available via the SEC’s website at www.adviserinfo.sec.gov The SEC’s website also provides information about any persons affiliated with TruVineFinancial who are registered, or are required to be registered as investment advisor representatives of TruVineFinancial, LLC
Item 3 – Table of Contents
Item 1 – Cover Page ………………..………………………………………………………..… 1
Item 2 – Material Changes …………………………………………………………………… 2
Item 3 – Table of Contents ……………………………………………………………………. 3
Item 4 – Advisory Business ……..………………………………………………………..…. 4
Item 5 – Fees and Compensation …………..…………………………….…………………. 5
Item 6 – Performance-Based Fees and Side by Side Management …..……..… 7
Item 7 – Types of Clients …….……………………………………………………………..…. 7
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ………. 8
Item 9 – Disciplinary Information ……………………………..………………………… 11
Item 10 – Other Financial Industry Activities and Affiliations …………..……. 11
Item 11 – Code of Ethics, Participation or Interest in Transactions and Personal Trading ………………………………………………………………………………………….. 12
Item 12 – Brokerage Practice …………………………………………………..……………. 14
Item 13 – Review of Accounts …………………………………………………………..….. 14
Item 14 – Client Referrals and Other Compensation ……………………………… 14
Item 15 – Custody …………………………………………………………………………….…. 15
Item 16 – Investment Discretion …………………………………………………..……… 15
Item 17 – Voting Client Securities …………………………………………………………. 15
Item 18 – Financial Information ……………………………………………….…………. 15
Item 19 – Requirements for State-Registered Advisors …….……………………. 16
Item 4 – Advisory Business
TruVine Financial was founded in 2017 as a Financial Planner by Tim Spuler. In 2018, Tim passed the Series 65 exam and in 2019 achieved the Chartered Financial Consultant (ChFC) certification. In addition to Financial Planning, TruVine also provides investment advisory services. TruVine Financial is organized as a Limited Liability Company under the laws of the state of New Jersey and is registered as an investment advisor in New Jersey and Pennsylvania.
Financial Planning as well as investment portfolios are designed to meet the individual needs of the client for a fee. Investment accounts can be Self Directed or Discretionary, which means the advisor has authority to make purchases and sale transactions in the client’s account at will, provided such transactions conform to the client’s investment objective and are conducted in a fiduciary manner, which means the client’s interest and well-being come first and are put ahead of the advisor’s.
All investment research is conducted in-house using data from known research publishers such as Morningstar™
We do not offer, recommend or sell proprietary products, commodities, partnerships, private placements or other illiquid, high-risk securities.
Clients may request restrictions on an account, such as when a client needs to keep a minimum level of cash in an account or does not want to buy or sell certain specific securities or security types in their account(s). TruVine reserves the right to not accept and/or terminate management of a client’s account if we feel that the client-imposed restrictions would limit or prevent us from meeting or maintaining the client’s investment strategy.
Should a possible conflict of interest arise, disclosure of the conflict will be made to the client.
TruVine can manage client assets in discretionary accounts on a continuous and regular basis. As of December 2019, TruVine has $2,400,000.00 of Assets Under Management (AUM) in discretionary accounts.
Item 5 – Fees and compensation
Fees for Financial Planning are invoiced to the client on an hourly basis at a rate of $150.00 per hour in arrears. Financial Planning can consist of one or more of the following services:
(a) Reviewing and prioritizing your goals and objectives; (b) Developing a summary of your current financial situation, including a net worth statement, cash flow summary, and insurance analysis; (c) Reviewing your current investment portfolio and developing an asset management strategy; (d) Developing a financial management strategy, including financial projections and analysis; (e) Completing a retirement planning assessment, including financial projections of assets required at estimated retirement date; (f) Assessing estate net worth and liquidity; (g) Identifying tax planning strategies to optimize financial position; (h) Presenting a written financial plan that will be reviewed in detail with you. It will contain recommendations designed to meet your stated goals and objectives, supported by relevant financial summaries (i) Developing an action plan to implement the agreed upon recommendations (j) Referral to other professionals, as required, to assist with implementation of the action plan; (k) Assisting you with the implementation of the financial plan (l) Determining necessity to revise your financial plan.
Fees for investment advisory services can be on an hourly basis per the rate stated above or can be invoiced monthly, in arrears, based on the value of the portfolio on the last business day of the previous billing cycle. Asset values of multiple accounts will be combined to reduce fees.
The basic fee schedule is as follows:
Assets Under managementent Annual %
Individual Equities, Mutual Funds, ETF’s, REIT’s: Values up to 1,000,000 .90%
Values over $1,000,000 .65%
Values over $5,000,000 .50%
Fixed Income Securities:
Corporate, Municipal, US Government .50%
Cash (includes Money Market Funds) .25%
U.S. Treasury Bonds No Fee
Clients have the option to purchase investment products that TruVine recommended through other brokers that are not recommended or affiliated with TruVine.
A client may incur additional expenses and fees, as a shareholder, if assets are invested in a mutual fund or exchange traded fund. These additional expenses may include: advisory/management fees, distribution fees, administrative expenses, and other fund operating expenses. Clients wishing to obtain additional fee information on a particular mutual fund or exchange traded fund may obtain this information by reviewing the relevant prospectus(es) for the underlying fund.
TruVine may provide portfolio management services to certain family members or friends without charge, or fee rates that are lower than the rates available to other clients.
Either party may terminate the TruVine Agreement (“Agreement”) at any time upon fifteen (15) days written notice. The client may terminate without a penalty within five (5) business days of entering into their Agreement. The client agrees that, upon termination, he/she shall have the sole responsibility for the assets in the account. Death, disability or incompetency of the client will not terminate or change the terms of the Agreement; however, the client’s executor, guardian, attorney-in-fact or other authorized representative may extend or terminate the Agreement by giving written notice to TruVine.
Upon termination of the Agreement, the client will receive a prorated invoice, which will be calculated based on the date that TruVine received notification of cancelation.
Invoices for monthly fees (hourly or based on assets under management) will be mailed within five (5) business days after the close of the billing cycle. Invoices will include the fee calculation and amount due.
All clients will receive brokerage statements directly from the custodian no less than quarterly.
Item 6 – Performance-Based fees and side-by side Management
TruVine does not charge any performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of the client).
Item 7 – Types of Clients
TruVine provides Financial Planning and Investment portfolio management services to individuals and high net-worth individuals.
TruVine does not maintain requirements for opening or maintaining an account, such as a minimum account size or minimum client net worth.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
It is our practice to invest in the best managed large, medium and small capitalized companies. These companies, over an extended period of time out-perform their respective benchmark.
When investing in fixed-income securities, we generally consider investment-grade corporate, US Government agency and / or tax-exempt bonds; however, based on the clients risk tolerance and the client’s need for higher cash flows, High Yield corporate instruments can be used to balance risk and reward requirements. In these cases, careful analysis is used to choose securities that have outstanding performance and the highest safety in their investment class. The investor who allocates a portion of account assets to these securities should be more aggressive and willing to tolerate additional volatility.
Investment strategies range from fixed income objectives with more conservative goals to equity objectives with more aggressive goals.
Equity investor’s primary goal should be to maximize long-term returns with a focus on capital appreciation and relatively little emphasis on current income.
Fixed income investor’s primary goal should be to generate income while conserving principal.
Equity securities generally have a greater potential for both higher risk and reward while fixed income securities offer more modest rewards with correspondingly less risk. Investing in securities carries with it the risk of loss of capital.
There is NO GUARANTEE that a particular strategy will meet its investment goals. The investment strategies and techniques TruVine uses within a given strategy will vary over time depending on various factors. TruVine may give advice and take action for clients which differs from advice given or the timing or nature of action taken for other clients with different objectives.
Summaries of investment objectives, principal investment strategies and material risks provided below are limited, and are presented for general information purposes in accordance with regulatory requirements. Consequently, these summaries are in all instances qualified and superseded by the descriptions of objectives, strategies and risks, portfolio reports, and other communications which are provided to each client in connection with the creation and maintenance of the client’s own account.
INVESTING IN SECURITIES INVOLVES RISK OF MONETARY LOSS, AND CLIENTS INVESTING THEIR MONEY WITH TRUVINE SHOULD BE PREPARED TO BEAR THAT LOSS. NONE OF THE STRATEGIES FOR WHICH TRUVINE PROVIDES PORTFOLIO MANAGEMENT SERVICES IS A DEPOSIT IN ANY BANK, NOR ARE THOSE INVESTMENT VEHICLES INSURED OR GUARANTEED BY THE FEDERAL DEPOSIT INSURANCE CORPORATION OR ANY OTHER GOVERNMENT AGENCY.
Equity Strategies: (Long-term capital growth)
Equity securities represent an ownership position in a company. Equity securities typically consist of common stocks. Prices for equity securities fluctuate based on events specific to the company, the macro and micro economy, governments and other conditions. Equity objectives primarily attempt to achieve capital appreciation and are managed more aggressively than securities managed primarily to achieve income. An investor’s time horizon should generally be long term – defined as 3 – 5 years or longer.
Some securities, depicted as Small Cap stocks (companies that have a market capitalization between $300 million and $2 billion) and some Mid Cap stocks (companies that have a market capitalization between $2 billion and $10 billion) may be slightly less liquid, i.e., experience lower trading volumes and greater spreads (the difference between the purchase price and the selling price of a share of stock). This may result in greater market volatility of these securities in comparison to Large Cap securities (companies that have market capitalization greater than $10 billion).
Due to the more aggressive and volatile nature of Small Cap and Mid Cap securities, Investors should generally have a higher tolerance for risk and the possibility of capital loss compared to investors that focus on Large Cap securities.
Equity Income Strategies: (Capital appreciation and income)
While this investment strategy is still associated with equity investments, the primary goal of the Equity Income investor should be capital appreciation and income, with a higher emphasis on capital appreciation. The objective is to attain most of the gains during general market appreciation, while also cushioning losses with income in general market declines. This investment strategy is less aggressive than the pure Equity strategy. The Equity Income investor should have a moderate tolerance for short-term volatility, and a time horizon similar to the pure Equity investor.
Material Risks associated with Equity Investing and Equity Income Investing: Management Risk; Market Risk; Economic Risk; Business Risk; Country Risk; Credit Risk; Interest Rate Risk; Liquidity Risk; Exchange Rate Risk; Tax Risk.
Balanced Strategies (Strategic Income and Select Balance): (Capital appreciation and income)
This investment strategy looks to balance capital appreciation and income but with a larger emphasis on income. The balanced account’s equity position is designed to accept some market risk, while keeping current with inflation.
The investor, in a balanced strategy, should be willing to accept periods of negative returns; however, the investor’s risk and volatility tolerance should be lower than an investor choosing an Equity or Equity Income strategy. An investor’s time horizon should generally be medium to long term – defined as 1 -3 years or longer.
Material Risks associated with balanced securities are similar to those previously discussed.
Fixed Income: (Generate current income while conserving principal)
Fixed Income investing strategies are generally more conservative than the Equity or Balanced investment strategies. While Equity investing is viewed as owning a part of a company, Fixed Income investing is viewed as a debt relationship. The company that you are investing in is borrowing money from you with a promise to pay you back your principal as well as interest. The Fixed Income investor generally seeks consistent returns (although lower than Equity and Balanced returns) with much lower risk. Because of the lower volatility, a Fixed Income investor may have a shorter investment time horizon than an Equity or Balanced investor however a Fixed Income investor may also have a long time horizon with a lower risk tolerance. While the volatility and risk may be lower, they still exist and investors may suffer loss of investment.
Material Risks associated with Fixed Income securities: Management Risk; Interest Rate Risk; Price Risk; Reinvestment Risk; Credit Risk; Liquidity Risk.
Item 9 – Disciplinary Information
Registered Investment Advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of TruVine Financial, LLC.
Neither TruVine Financial, LLC nor Tim Spuler has been the subject of any material legal or disciplinary action.
Item 10 – Other Financial Industry Activities and Affiliations
Tim Spuler is a Financial Planner in the state of New Jersey. He maintains an independent Financial Coaching Certification with Ramsey Solutions™, a Dave Ramsey organization, and also coordinates Financial Peace University ™, a nine (9) week class on personal financescreated by the Dave Ramsey organization.
While serving as the Chief Financial Officer of a Philadelphia based auto parts remanufacturer, Tim Spuler created many strong relationships with Investment Advisors, Financial Planners, Bankers, Accountants, Lawyers, Insurance Agents / Brokers, Pension Consultants and Real Estate Brokers. While these relationships have been valuable and beneficial from a knowledge perspective, any recommendation to clients of the above professionals is done without any direct or indirect material compensation to Tim Spuler or TruVine Financial, LLC., and does not create any material conflicts of interest.
Item 11 – Code of Ethics
A Code of Ethics spells out how one person or company will act towards another. In the Financial Industry, Financial Advisors and Planners are held to a Fiduciary standard which means to put the client’s interest first! At TruVine Financial, we hold ourselves to strict standards of ethical behavior. This Code of Ethics provides the standards that guide our conduct, as we serve our clients.
C – Clients come first. Our role is to fully understand our client’s dreams, financial risk tolerance, capabilities and obligations in order to convert these into achievable goals, while maintaining confidentiality.
O – We will remain objective. Objectivity requires honesty and impartiality. While conducting our work, we will maintain our integrity, professionalism and will avoid any outside influences that might bias the facts.
D – Disclosure of information. We treat our client’s information as if it were our own, avoiding any disclosure unless authorized or legally required. We will not take advantage of any non-public personal information for our own benefit. We will avoid or disclose in writing any conflicts of interest, and disclose any and all material facts about TruVine Financial, LLC.
E – Ethical behavior. While this entire Item 11 spells out ethical behavior and moral character, it is important to call out a common term that is synonymous with ethical behavior. That is the Golden Rule. We will act in a manner that reflects… “Do unto others as you would have them do unto you.” We will not take unfair advantage of clients through manipulation or dishonest dealings, abuse of privileged or confidential information, misrepresentation of material facts or any other unfair practices.
E – Earn the client’s trust. We will work to earn the client’s trust and respect. We will never demand it or treat the client in a demeaning way as to make them feel less important. We will work with diligence, providing prompt and thorough service.
T – Communicate truthfully. Sometime the truth hurts, but if we do not provide truthful communication, the pain from wrong communication could be worse. We will act and communicate honestly in proper service to our clients in an effort to help them fulfill their goals and dreams.
H – God honoring. We will act in a way that honors our faith in God, who provides for all of our daily needs.
I – Act, live and work with integrity. Clients place their trust in the services and information we provide and therefore they demand personal honesty and integrity. We will work in a way that provides no tolerance for deceitful behavior.
C – Maintain a competent skill set. We will attain and maintain a level of knowledge that the client expects and apply that knowledge and skill to the services provided. When specific knowledge is lacking, we will have the wisdom to seek that knowledge or the wisdom to refer a client to someone who is better able to assist the client.
S – Serve the client. We end this code of ethics in a similar manner in which we started…The client comes first and therefore our efforts are to serve them and to meet their needs. Our recommendations to our clients must be appropriate and specific to them and their circumstance or personal situation.
TruVine Financial or Tim Spuler may buy or sell securities for themselves that are also recommended to clients; however, our Code of Ethics guides us to continually put the client first and as such, TruVine Financial should not generate any personal benefit from similar recommendations
Item 12 – Brokerage Practice
TruVine Financial recommends TD Ameritrade, Inc. (“TD”) and/or Fidelity Investments, Inc. (“Fidelity”) to act as broker or agent to effect securities transactions; however these are only recommendations. Any client may select any broker or agent they feel best meets their needs. Both TD and Fidelity are unaffiliated with TruVine. They provide services to independent investment advisors such as custody of securities, trade execution, clearance and settlement of transactions.
As a result of our relationship with TD and Fidelity, TruVine may receive certain economic benefits and services related to the referral of clients to TD or Fidelity. (see item 14 below for details)
Receipt of these benefits and services will in no way diminish TruVine’s obligation to act in a fiduciary manner to its clients at all times, including making sound and appropriate investment recommendations and ensuring execution of trades for client accounts.
TruVine will conduct periodic reviews of its relationships to ensure they are continuing to provide high-value services to our clients and remain competitive with other service providers.
Item 13 – Review of Accounts
Account reviews are conducted at least quarterly. Off-cycle reviews may be conducted by a change in investment strategy by the client, a life change event of the client or immediate family member, or a significant change to any asset(s) within the portfolio.
Item 14 – Client Referrals and other Compensation
As mentioned in Item 12 above, TruVine recommends TD or Fidelity for custody and brokerage services. While TruVine may recommend TD or Fidelity, TruVine has no agreement with either and does not receive any additional economic benefits through its relations.
Item 15 – Custody
TruVine does not have Custody of client funds or securities, but does maintain Limited Custody, which is defined as having the ability to deduct client fees from the client’s account maintained at a qualified custodian.
Prior to having fees deducted via a qualified custodian, TruVine will:
- Possess written authorization from the client to deduct advisory fees from an account held by a qualified custodian.
- Send the qualified custodian written notice of the amount of the fee to be deducted from the client’s account.
- Send the client an itemized invoice including any formulae used to calculate the fee, the time period covered by the fee, and the amount of assets under management on which the fee was based.
TruVine does not prepare client statements. Statements are provided to the client by the Custodian, at a minimum, on a quarterly basis. On-line statements for prior periods are available through the Custodian’s website. Clients should review statements carefully and report any discrepancies to the Custodian and TruVine immediately.
Item 16 – Investment Discretion
TruVine can maintain discretionary authority over investment advisory accounts in accordance with the terms of the management agreement to select the asset(s), the activity (buy or sell) and the amount of assets to be transacted on behalf of the client. In all cases, such discretion is exercised in a manner consistent with the client’s stated investment objectives and risk tolerance.
Item 17 – Voting Client Securities
TruVine does not have authority to vote proxies on behalf of advisory clients. Clients retain responsibility for receiving and voting proxies for any and all securities maintained in the client’s portfolio(s) directly from the issuer or custodian. TruVine may provide advice regarding voting proxies if asked.
Item 18 – Financial Information
TruVine does not solicit prepayments of more than $500.00, six (6) months or more in advance for services provided. There are no known conditions that are reasonably likely to impair TruVine’s ability to meet contractual commitments to our clients. Neither TruVine Financial, nor Timothy Spuler have been the subject of a bankruptcy petition at any time.
Item 19 – Requirements for State-Registered Advisers
TruVine has registered with the state of New Jersey and Pennsylvania. Application for registration in other states will be made if necessary.
Principal Executive Officers and Management Persons:
TruVine Financial is a single member LLC. Tim Spuler is the Managing Member and the sole employee of the company.
Other Business Activities:
TruVine Financial is first and foremost a Financial Planner. Times allocated to Financial Planning and general business consulting account for approximately 90% while time allocated to Investment Advisory services account for approximately 10%.
Performance Based Fees:
TruVine does not receive any performance-based fees.
Legal and Disciplinary Issues
TruVine Financial seeks to maintain the highest level of business professionalism, integrity and ethics. Neither TruVine, nor Tim Spuler have any legal or disciplinary events on our records to disclose.
Arrangements with Securities Issuer’s:
Neither TruVine, nor Tim Spuler have any relationships or arrangements with issuers of securities.
