TRANSATLANTIQUE PRIVATE WEALTH LLC

Item 1: Cover Page Firm Brochure (Part 2A of Form ADV) Transatlantique Private Wealth, LLC 520 Madison Avenue, 37th Floor New York, NY 10022 t – (212) 644-4219 f – (212) 644-7504 This Brochure provides information about the qualifications and business practices of Transatlantique Private Wealth, LLC. If you have any questions about the contents of this Brochure, please contact us at: (212) 644-4219, or by email at: xavier.volatier@banquetransatlantique.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. Additional information about Transatlantique Private Wealth, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Transatlantique Private Wealth LLC is a registered investment adviser. Registration of an Investment Advisor does not imply that the company or any of its management has achieved a certain level of skill or training. March 26, 2025  Item 2: Material Changes Annual Update This Material Changes section of the Brochure will be updated annually and as soon as a material change occurs to this Form ADV Part 2 and any subsequent release of this Brochure. Material Changes since the Last Annual Update Since the last other-than-annual amendment, dated June 24, 2024, the Firm has updated Item 14 to include client referrals arrangements. Full Brochure Available Whenever you would like to receive a current complete copy of the Transatlantique Private Wealth, LLC Firm Brochure, please contact us by telephone at: (212) 644-4619; or, by email at: xavier.volatier@banquetransatlantique.com.  Item 3: Table of Contents 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 ............................................................................................ 7 Item 6: Performance-Based Fees ......................................................................................... 10 Item 7: Types of Clients ...................................................................................................... 10 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .................................... 10 Item 9: Disciplinary Information ......................................................................................... 15 Item 10: Other Financial Industry Activities and Affiliations ............................................... 15 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............................................................................................................................. 17 Item 12: Brokerage Practices .............................................................................................. 18 Item 13: Review of Accounts ............................................................................................... 19 Item 14: Client Referrals and Other Compensation ............................................................ 20 Item 15: Custody ................................................................................................................ 20 Item 16: Investment Discretion ........................................................................................... 21 Item 17: Voting Client Securities ......................................................................................... 21 Item 18: Financial Information ........................................................................................... 21  Item 4: Advisory Business Firm Description Transatlantique Private Wealth, LLC (“TPW,” the “Firm,” “Adviser”) is a New York limited liability company and an SEC registered investment advisory firm with its primary office in New York, New York. The Firm was formed in December 2013 and commenced business operations on April 4, 2014. TPW is wholly owned by Banque Transatlantique S.A., a bank headquartered in Paris, France (“Banque Transatlantique”), that specializes in private banking services and wealth management. Banque Transatlantique is a wholly owned subsidiary within the Credit Mutuel Alliance Federale group of companies domiciled in France and Europe. Banque Transatlantique is owned 100% by CIC (Credit Industriel et Commercial), which in turn is 93% owned by Banque Federative de Credit Mutuel (“BFCM”), which itself is 92% owned by Caisse Federale de Credit Mutuel. As of December 31, 2024, TPW manages approximately $676,186,819 in Regulatory Assets Under Management, $667,059,767 on a discretionary and $9,127,051 on a non-discretionary basis. Types of Advisory Services TPW provides investment advisory services on a non-discretionary and discretionary basis primarily to high net worth individuals with international investment exposure. TPW is in a position to assist such investors to maneuver through the cross-border intricacies between the USA and France. Accordingly, the Firm’s target client base is mainly French expatriates in the United States and U.S. persons owning euro denominated assets and property. The Firm creates asset allocation plans for its clients and assists them to distribute their investments across the various asset classes. TPW is also able to offer tailored advice that leverages the expertise of TPW’s affiliated companies in France and Europe. The Firm’s advisory services are typically provided to individual clients as an ongoing service pursuant to an Advisory Agreement. Such services may include advice and guidance on debt management; currency management; risk management; long-term project funding and, investment portfolio construction. The investment advisory fee is the only fee the Firm charges (see Item 5: Fees and Compensation). In some instances, advice may be provided as a limited engagement that focusses on a specific investment or financial issue, rather than comprehensive portfolio management, at the request of the client and at the sole discretion of the Adviser. The Firm may also provide to certain high-net worth individuals the opportunity to have their portfolios managed by a sub-adviser, which may be engaged by the Firm. TPW would monitor the performance of any such independent manager on behalf of the advisory client, in terms of the manager’s authority to operate in the jurisdiction in which the client resides as well as in terms of matters including the manager’s expertise relative to the client’s needs. TPW also advises two commingled investment vehicles: The Philippe Fund Euro Global Leaders, LLC and The Philippe Fund U.S. Equities, LLC (together the “Commingled Funds”). Certain TPW clients, who are deemed ‘accredited investors’, may invest in the Commingled Funds, pursuant to a subscription agreement. All clients are required to sign an Advisory Agreement outlining the terms and conditions of the engagement as described below. TPW will provide a copy of this Brochure (Form ADV Part 2) to each client prior to the execution of an Advisory Agreement. Any client, who does not receive a copy of the current TPW Brochure at least 48 hours prior to executing the Advisory Agreement, is permitted five business days to rescind the engagement without penalty.  TPW does not at this time participate in wrap fee programs, whether recommending that its clients participate in them or by providing portfolio management services to such programs. Tailored Relationships and Restrictions The nature of TPW’s primary advisory business is that it tailors its advisory services to the specific needs of the client. Based on suitability information gathered for a particular client, including financial condition, investment objectives, investment risk profile and other factors that may be relevant to the proposed investments by a client, TPW will advise the client about the allocation of their assets into specific investments across different forms of investments and investment managers, including, without limitation, designation of other portfolio managers, who will actually invest and reinvest within specified asset classes on behalf of the client. There is a $300,000 portfolio minimum. (see Item 7: Types of clients). In terms of the Firm’s advisory fee schedule, current client relationships may exist where the fees are higher or lower than the fee schedule, due to a negotiated rate. However, in no event would the TPW advisory fee charged to a client ever be greater than 3% of client Assets Under Management (“AUM”) (see Item 5: Fees and Compensation below). On an ongoing basis, the Firm will monitor the performance in a client’s portfolio after the initial Asset Allocation Plan is implemented and report that performance to the client, whether quarterly, or at intervals requested by the client. TPW would also recommend from time to time modifications to the Plan. In the context of this asset allocation approach, TPW will tailor its services to the needs and desires of the individual client. Clients may ask that certain investment restrictions be placed on their accounts. It is the policy of TPW to agree to client-imposed investment restrictions only if the clients and TPW are able to agree upon restrictions that are clear and actionable. TPW will ensure that where possible the advisory client will provide a list of prohibited securities (e.g., Anheuser Busch, etc., instead of a list of types of prohibited securities such as "sin stocks," etc.). Where only restrictions on the types of securities are agreed-to, TPW requires as much written specificity as possible (e.g., brewing of alcoholic beverage or distribution of liquor, or both). Where a client places specific restrictions on the account, there will be a specific contractual provision in the Advisory Agreement addressing prohibited investments that obligates TPW to make its “best efforts” to comply with the client restriction. TPW allocation approach follows Group Credit Mutuel Alliance Federale investment policies which incorporate sector restrictions based on ESG criteria. Investment & Wealth Advisory Services TPW’s ongoing advisory services can be enhanced for wealthier clients into an overall analysis of the client’s financial circumstance. These services are typically provided to clients with net worth in excess of U.S. $1,000,000 and/or with the specific need for professional expertise in regard to the cross border financial issues affecting the United States and France. No additional fee would be charged for such services. TPW will propose an asset allocation plan based on a suitability profile derived from a thorough review of the client’s financial situation and objectives as well as the client’s level of risk aversion. Independent Managers TPW may recommend that a client allocates a portion of its assets across independent investment managers, unaffiliated with TPW, in accordance with the client’s approved asset allocation plan. In such situations, the independent managers would have primary day-to-day management responsibilities for the active discretionary management of the allocated assets in a separate account. TPW would remain responsible for monitoring the performance of these sub-advisers on behalf of the advisory client to ensure that the account remains properly allocated, and the investment objectives of the client and performance of the account remain in accordance  with the overall plan. Factors that TPW considers in recommending these sub-advisers include the client’s investment objectives, the adviser’s management style, performance, reputation, financial strength, reporting, and research capabilities. Implementation TPW offers investment advice on a discretionary and non-discretionary basis. For accounts managed on a non-discretionary basis, the advisory client makes all final decisions regarding the implementation of investment recommendations, including the determination of the timing and execution of portfolio trades. TPW provides its advice and the client retains absolute discretion over the implementation of portfolio management. The client is always free to accept or reject a recommendation by TPW. For accounts managed on a discretionary basis, please refer to Item 16. Investment Discretion within this brochure. Other Services TPW may provide as part of its advisory services to its clients information regarding non-investment related matters, such as estate planning, insurance, etc. No additional fee would be charged for such services. Neither TPW, nor any of its representatives or affiliates, purports to provide accounting advice. To the extent requested by an advisory client and within the available expertise of the Firm, TPW may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, etc.). The advisory client, of course, retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from TPW. Advisory Agreement TPW does not conduct Financial Planning or Tax Preparation services. TPW’s traditional business model is to offer clients asset allocation construction services across the agreed-upon asset classes. Investment Advisory Agreements All clients receive and sign the Advisory Agreement at the commencement of the advisory relationship. The Firm will work with the client to understand the client’s suitability profile and will develop with the client an asset allocation plan, whereby the TPW portfolio manager will then recommend securities of various asset class or will recommend external portfolio managers. Conflicts of Interest One of the main purposes of this Form ADV Part 2A is for TPW to be able to fully and properly present its investment advisory services AND to fully and clearly disclose any material conflicts of interest that may exist between the interests of the Adviser and the advisory client. State and federal laws and regulations provide that failing to disclose to an advisory client in writing before entering or renewing an advisory agreement with that client any material conflicts of interest regarding the Adviser, its representatives or any of its employees, which could be reasonably expected to impair the rendering of unbiased and objective advice does not promote fair, equitable or ethical principles. Accordingly, this Form ADV Part 2A is intended by the Adviser to disclose all material conflicts of interest to the advisory client. Termination of Agreement TPW’s Advisory Agreements can be terminated by either the client or the Firm, upon written notice of termination from either party to the other, or as otherwise agreed between the client and TPW. If termination occurs other than at the end of a quarter, TPW will be entitled to its investment advisory fee for the portion of the quarter elapsed prior to termination, pro-rated based on the actual number of calendar days in that specific calendar quarter and the actual number of calendar days elapsed in that calendar quarter.  Item 5: Fees and Compensation Description The investment advisory fee payment structure requires advisory fees to be pay quarterly, in arrears. We will either deduct fees directly from client custodial accounts or invoice clients. Fees for asset allocation services are calculated in arrears on the first day of each subsequent calendar quarter (January 1, April 1, July 1 and October 1). Investment advisory fees are NEGOTIABLE. Lower fees for comparable services may be available from other sources. The investment advisory fee is calculated on a quarterly basis based on the market value of the account on the last business day of the quarter. The fees are payable on the first day of each subsequent calendar quarter (January 1, April 1, July 1 and October 1), or on a semi-annual basis depending on the custodial arrangement in place. Advisory Fees All clients receive at the opening of their account the advisory fee schedule contained herein this Brochure. An advisory client’s investable assets as to which TPW gives advice are referred to in the Advisory Agreement as the client’s “Account.” To clarify, if the client has more than one account with TPW for which an investment advisory fee is charged, then the fees computed, including fees charged on new assets and refunds given on withdrawn assets will be based on the combined value of all of the client’s accounts. Accordingly, the group of accounts, for which the Advisory Agreement is made and the fee is calculated, are referred to as the “Account.” Each Advisory Agreement is entered into by the volition of each party and able to be terminated by either party (see the Termination of Agreement section below). In terms of the Firm’s advisory fees schedule, current client relationships may exist where the fees are higher or lower than the fee schedule below due to a negotiated rate. However, in no event would the TPW advisory fee charged to its clients ever be greater than 3% of client AUM. The current TPW investment advisory fee for asset allocation advisory services is computed as follows: • 0.30% of assets per quarter (approximately 1.20% per annum) on assets up to and including $1 million0.25% of assets per quarter (approximately 1.00% per annum) on assets over $1 million and up to and including $2.5 million; • 0.1875% of assets per quarter (approximately 0.75% per annum) on assets over $2.5 million and up to and including $5 million; and • 0.125% of assets per quarter (approximately 0.50% per annum) on assets over $5 million and up to and including $10 million. For assets managed under TPW’s Transatlantique Allocation Yield strategy: • 0.175% of assets per quarter (approximately 0.7% per annum) on assets up to and including $1 million; • 0.15% of assets per quarter (approximately 0.6% per annum) on assets over $1 million and up to and including 5 million; • 0.125% of assets per quarter (approximately 0.50% per annum) on assets over $5 million For the Municipal Bond asset class: • 0.10% of assets per quarter (approximately 0.4% per annum) on assets up to and including $1 million;  • 0.0875% of assets per quarter (approximately 0.35% per annum) on assets over$1 million and up to and including 5 million; • 0.075% of assets per quarter (approximately 0.30% per annum) on assets over $5 million. Regardless of the assets allocations, fees on assets over $10 million are negotiable. The investment advisory fee is calculated on a quarterly basis based on the market value of the account on the last business day of the quarter. The fees are payable on the first day of each subsequent calendar quarter (January 1, April 1, July 1 and October 1), or on a semi-annual basis depending on the custodial arrangement in place. Advisory clients, who invest in the Commingled Funds, or other investment products managed by TPW or an affiliate of TPW will have an equivalent amount excluded from the value of their account assets for the purposes of TPW’s calculation of the management fees or will receive a credit for management fees paid at the fund or product level. In this way the advisory client would not be charged an additional fee in connection with their assets under management. Brokerage fees will typically be charged to the advisory client’s account in addition to the advisory fee by brokers, dealers, or other market intermediaries having the required registrations and/or authorizations in the relevant jurisdictions, including affiliates of TPW, for the execution of day to day buy and sell orders. For additional information regarding brokerage please see the Brokerage Practices section of this Brochure below. Advisory clients would typically also pay custodial fees in addition to the advisory fee. For additional information regarding the fees charged by the custodian of your account, including any charges relating to foreign exchange transactions or how your custodian handles foreign exchange transactions relating to your account, you should contact your custodian or refer to any agreement you have entered into with your custodian. Other charges that the advisory client may incur relating to their account may include exchange fees, stamp duties and/or taxes on securities transactions. Exchange traded funds also charge internal management fees, which are disclosed in the funds’ prospectus. Such charges, fees, and commissions are exclusive of and in addition to the advisory fees described herein. TPW does not charge any fees other than the advisory fee. If TPW recommends a non- affiliated outside manager to manage some or all of a client’s assets as part of an overall asset allocation plan, there would be a fee share arrangement between TPW and the outside manager that would compensate either party. TPW is not compensated by outside managers or funds for recommending such money managers to the advisory client. TPW Direct Management VS. Management by Non-Affiliated Outside Manager TPW may manage client assets directly and/or may recommend non-affiliated outside managers (“outside managers”). TPW may select, exchange-traded funds and other products. In addition to the advisory fee charged by TPW, and exchange-traded products have their own management fees. The end result is a higher combined fee paid by the client as opposed to assets being managed by outside managers. When TPW recommends that client assets are managed by outside managers, the fees payable under their agreement with TPW shall include the advisory fee paid to the outside manager. In other words, when TPW recommends client assets to be managed by an outside manager, the outside manager’s fee is covered by the agreed upon fee charged by TPW, so the fee will not exceed the TPW fee schedule as disclosed in Item 5: Fees and Compensation. In accounts managed by outside managers, TPW’s primary role is one of monitoring client transactions that are executed by outside managers.  Furthermore, outside managers will select individual securities, so no underlying advisory fees are assessed, as would be the case for Exchange-traded funds managed directly by TPW. Commingled Fund Fees and Expenses Pursuant to an Investment Management Agreement, as compensation for acting as the Manager of the Fund and managing the Fund's securities portfolio and any other Fund assets and performing administrative services for the Fund (including acting as the transfer agent for the Fund), the Fund will pay TPW a management fee (the "Management Fee"), payable quarterly in arrears, equal to one quarter of one percent of the net asset value of the Fund over the preceding quarter (based on the market value of the portfolio as of the end of each month during such quarter). The Management Fee will be pro-rated for the final quarter of the Fund if it covers less than one hundred twenty (120) days. In the case of investment in another fund managed by TPW, the Management fee will be reduced by the portion of the fee allocable to such investment and paid to TPW by such other fund. The Fund will pay directly or reimburse TPW for all costs and expenses related to the Fund's operations and the purchase, sale and retention of the Fund's portfolio securities and any other assets, including, but not limited to, the costs and expenses of brokerage, any credit facility and any other borrowings, interest payments, securities lending, clearing and settlement and legal, audit and accounting services. TPW will bear, and the Management Fee will be payment for its provision of, the following administrative expenses of the Fund: office space and equipment, utilities, administrative services and secretarial, clerical and other personnel. TPW will reduce the AUM of any advisory account that invests in the funds above by the amount invested to ensure the client does not incur a double fee. Fee Billing As stated above, the investment advisory fee for asset allocation services is calculated in arrears on a quarterly basis based on the market value of the account on the last business day of the quarter. The fees are payable on the first day of each subsequent calendar quarter (January 1, April 1, July 1 and October 1) or on a semi- annual basis depending on the custodial arrangement in place. Direct Payment of Fees TPW’s advisory clients may elect to expressly authorize the “qualified custodian” of their assets, as defined in Rule 206(4)-2 under the Investment Advisers Act of 1940, as amended, to pay any and all fees due to TPW under the TPW Advisory Agreement directly from the client’s assets without prior notice to the client, subject to satisfaction of all relevant conditions of Rule 206(4)-2. Additions or Withdrawals of Assets after the Beginning of a Quarter If a client places additional securities or cash in the TPW account after the beginning of a quarter, an additional advisory fee will be charged on the new assets, on a pro-rata basis, for the remaining days in the quarter. The fee will be calculated based on the market value of the client’s account on the day of, and giving effect to, the additional contribution. It will reflect any breakpoints applicable to the new aggregate market value as described in the TPW Fee calculation schedule (in the Fees and Compensation section above), and will be payable on the day the additional assets are added to the account for asset allocation clients. Other Fees TPW does not charge any fees to client accounts other than the investment advisory fee. Custodians or transacting brokers may charge transaction fees on purchases or sales of securities and exchange-traded funds. TPW, in its sole discretion, may charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with clients, etc.).  Expense Ratios, Management and Performance Fees Alternative asset managers, and investment advisers generally charge a management fee for their services as investment managers of pooled investment vehicles. A mutual fund’s Prospectus and Statement of Additional Information and a private fund’s Offering Memorandum describe in detail all of a fund’s suitability requirements, risks, investment practices, and fees charged. No investment in a fund should be made without a complete reading and understanding of the risks. Performance figures quoted by mutual fund companies in various publications are after their fees have been deducted. Item 6: Performance-Based Fees Sharing of Capital Gains TPW does not charge performance fees of any kind. Its investment advisory fees are NOT based on a share of the capital gains or capital appreciation of client assets that it advises. TPW does not use a performance-based fee structure because of the potential conflict of interest. Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client. Item 7: Types of Clients Description TPW generally provides investment advice to High Net-Worth Individuals, Family Offices, Endowments and Foundations, Trusts, Estates, and other Charitable Organizations. Client relationships vary in scope and length of service. Account Minimums Each Advisory Agreement is entered into by the volition of each party and can be terminated by either party (see the Termination of Agreement section above). Each investment strategy require $300,000 account minimum to open a client account. Advisory fees are NEGOTIABLE. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis, Sources of Information, and Investment Strategies TPW offers consulting services with respect to asset allocation and asset management. In addition, the Firm may arrange for interested clients to engage sub-advisers or external managers, to manage directly the equity portfolios of its advisory clients on a discretionary basis in separately managed accounts. TPW will propose an asset allocation plan based on a suitability profile derived from a thorough review of the client’s financial situation and objectives as well as the client’s level of risk aversion and any agreed-to restrictions. There is no guarantee that the asset allocation plan developed by TPW will meet the needs of the advisory client. This disclosure brochure, and specifically this section and the Risk of Loss section below, are intended to make clear the risks inherent in investments. Investing in securities involves risk of loss that clients should be prepared to bear. TPW will explain its reasoning each time it presents its asset allocation plan to you, the client, both on the asset allocation plan level and on each mutual fund or outside manager chosen. However, risks include: the fact that any mutual fund and/or an outside manager that TPW ultimately recommends is not •  affiliated or under the control of TPW. Accordingly, once decisions are made as to the allocation plan the day-to-day management of the underlying portfolio is in the hands of the fund or adviser chosen, not TPW; • the performance of the securities markets cannot be predicted. Accordingly, the forces that work upon the market affect the performance of the underlying securities, regardless of the fundamental or technical health of a security and its performance. See the Risk of Loss section below; • there can be no guarantee that any investment strategy recommended by the Firm will perform as expected. All investment programs, however they may be designed to mitigate volatility and risk of loss, have certain risks that are borne by the investor. See the Risk of Loss section below. TPW leverages the experience of its professional staff and affiliated company analysts and advisory personnel to create proprietary analytical modeling, in order to create efficient client portfolios designed to achieve both short and long-term investment goals through the asset allocation of a client’s account across what the Adviser considers the most appropriate fund managers or sub-advisers. Regardless of the level of professional care and risk analysis and avoidance practiced by the Firm, which is designed to mitigate volatility and risk of loss, the fact remains that investments in securities, such as equities, fixed income, exchange traded funds containing these and other securities and contracts, involve risk of loss that the client should be prepared to bear. Please see the Risk of Loss section below to find out more about Risk. Investment Philosophy Strategic Allocation Process The TPW Strategic Allocation process starts with a detailed suitability profile of the advisory client. This information is coupled with the world view developed by the Firm’s affiliated research teams in Paris, Lille, and Luxembourg. Our teams analyze the global macroeconomic cycles and changes that affect the securities markets, as well as the evolving, dynamic variables of the markets (such as capital flows). They examine and research a convergence of information in order to establish one or more related scenarios, allowing them to define the major investment themes, which can then be implemented in the various different investment profiles. TPW investment professionals would then apply one or more of these thematic strategies to your investment profile. The conclusions that our affiliated research teams reach represent the cornerstone of the strategy that will be used in TPW’s portfolio construction. Monitoring: Detecting the Trends This step in the process of developing the philosophy behind your asset allocation plan consists of determining the growing markets, potential asset classes, corporate management strategies, and the appropriate investment choices. Economic and Financial (Fundamental) Analyses Here analysts marry macroeconomic analysis (top-down) with the microeconomic vision (bottom-up). Different economic indicators (unemployment rate, GDP growth, inflation rate, household consumption, etc.) and data specific to each sector or asset class (rating, growth or margins and results, market valorization, flow, liquidity, volatility, etc.) are analyzed in order to define the impact of potential economic scenarios and to determine the positioning of the sector or of the geographic zone in the economic cycle. Fundamental analysis focuses on measurable aspects of a company, its securities, peers, and the markets in  order to determine future stock prices by understanding and measuring the value” of a company and its securities. There is no guarantee that the fundamental analysis of a company, however, complete will yield favorable stock performance, hence favorable performance of your portfolio. Technical Analysis This step enables the analysts to anticipate or to measure the directional movements or sector rotations, which might be taken by different asset classes (indexes, rates, currency). In line with your investment profile, this stage helps to detect the trends, which might be flourishing in the coming months and to determine the allocations that would be chosen. Technical analysis is based solely on the study of stock charts, where it is believed that the past action of the security and the market will determine the future course of the price of the security. Technical analysts believe securities move according to very predictable trends and patterns. There is no guarantee that the technical analysis of a security and its charts will yield favorable portfolio performance in the future. Conclusions From these analyses TPW’s affiliated research teams are able to develop conclusions about the global economies and markets and how the best scenarios can be exploited by your particular investment profile. Once these teams have conviction these models can be applied by TPW’s investment professionals. Fundamental and technical analyses provide a sound basis upon which advisers can inform investment recommendations decisions. But there are no guarantees of success. Risk of Loss All investment programs, however they may be designed to mitigate volatility and risk of loss, have certain risks that are borne by the investor. TPW’s investment approach constantly keeps the risk of loss in mind. Asset Allocation Plans developed by TPW for a client and the asset managers recommended to execute that Plan in a specific asset class are chosen with the intention to reduce the volatility of a portfolio and the risk of loss to the client. Client accounts are managed with a long-term perspective in mind. Shorter-term volatility even in the highest quality equity portfolio is to be expected, however. Investors in securities, whether public or private, face the following investment risks: • Interest-Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Market Risk: The price of a security, equity, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events. • Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities.  • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties and private equity investments are not. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. • Structured Products Risk: These products often involve a significant amount of risk as they are often times based on derivatives. Structured products are intended to be "buy and hold" investments and are not liquid instruments. • Terrorism Risk—The prevalence of terrorist attacks throughout the world could have significant adverse effects on the global economy and may exacerbate some of the general risk factors related to investing in certain strategies. The likelihood of these types of events occurring in the future cannot be predicted nor how such events may affect the Firm. TPW has established risk management practices and business continuity plans designed to reduce the risks associated with terrorism. However, there is no guarantee that such efforts will succeed, and the Firm could be negatively impacted as a result. • Cybersecurity—TPW, the Commingled Funds, and their third-party service providers are subject to cybersecurity risks. Cybersecurity risks have significantly increased in recent years, and TPW, the Commingled Funds, and their third-party service providers could suffer material losses relating to cyber-attacks or other information security breaches in the future. The computer systems, software and networks of TPW and its third-party service providers may be vulnerable to unauthorized access, computer viruses, or other malicious code and other events that could have a security impact. If one or more of such events occur, this potentially could jeopardize confidential and other information of TPW and the Commingled Funds, or otherwise cause interruptions or malfunctions in TPW’s or the Commingled Funds’ operations or the operations of their third-party service providers. This could result in financial losses to TPW clients and the Commingled Funds investors. In addition, substantial costs may be incurred in an attempt to prevent future cyber incidents. TPW has established risk management systems and business continuity plans designed to reduce the risks associated with cybersecurity. However, there is no guarantee that such efforts will succeed, and Advisory client accounts and the Commingled Funds could be negatively impacted as a result. The following is a summary of the material risks for investment strategies and methods of analysis of the Commingled Funds. The information contained in this Brochure cannot disclose every potential risk associated with an investment strategy, or all of the risks applicable to the Commingled Funds. Rather, it is a general description of the nature and risks of the Commingled Funds’ investment strategies. Investors should understand that an investment in a Commingled Fund involves risk of loss, including the potential loss of their entire investment. No guarantee is made that the Commingled Funds’ investment objectives will be achieved. Prospective investors should carefully review the Offering Documents of a particular Commingled Fund for additional information on the risks associated with an investment in such Commingled Fund.  Material Risks • Risk of a Single Investment—The investment performance of a Commingled Fund will depend almost entirely on the performance of the applicable Underlying Fund, over which TPW will have no influence or control. Investors will have no right or power to influence, control, or participate in the day-to-day management of the Commingled Funds. The Commingled Funds will not hedge the risks of any of the underlying investments and TPW does not intend to take any defensive actions in the event of declining performance, with the exception of exercising its right, as a fiduciary, to dissolve or wind up a Fund. • Past Performance; No Guarantee of Future Results—The past investment performance of the Commingled Funds should not be construed as an indication of the future results of the Commingled Funds. Past performance is no assurance of future returns. • Dependence on Key Personnel—The Commingled Funds may rely on certain key personnel of TPW. The departure of any of such key personnel for any reason, including relating to work visas, compensation, or other factors, or the inability of such key personnel to fulfill certain duties, may materially and adversely affect the ability of TPW to effectively implement the investment programs of the Commingled Funds. • Limited Liquidity of Units—An investment in a Commingled Fund provides limited liquidity since Commingled Fund interests are not freely transferable and are subject to the restrictions on redemptions described in the Offering Documents. An investment in a Commingled Fund is suitable only for certain sophisticated investors that will not be materially impacted thereby. • Valuation of the Commingled Funds’ Investments—The Commingled Fund may, directly or indirectly, invest in assets that lack a readily ascertainable market value, and the net asset values of the applicable Commingled Fund will be affected by the valuations of any such assets. Given the uncertainty inherent in the valuation of assets that lack a readily ascertainable market value, the value of such assets as reflected in the net asset value of the Commingled Fund may differ materially from the prices at which the Commingled Fund would be able to liquidate the assets. • Differing Arrangements with Investors; Side Letters—The Commingled Funds and TPW may grant certain investors (including TPW employees) certain additional and/or different rights (including, without limitation, with respect to fees, minimum investment amounts, and access to information) than are offered to other investors through the issuance of a new class, side letters, or similar arrangements, or otherwise. As a result of such arrangements, certain investors may receive certain rights (including, but not limited to, expanded informational rights) which other investors may not receive. • Legal, Tax, and Regulatory Risks—TPW and the Commingled Funds are subject to legal, tax, and regulatory oversight, including by the SEC and the CFTC. New or revised regulations may result in increased costs, reduced profit margins, and reduced investment opportunities, all of which may negatively impact the performance of the Commingled Funds. In addition, there may also be unanticipated and/or adverse legal, tax, and regulatory changes, including changes in the interpretation or enforcement of existing laws and rules, from time to time, including requirements to provide additional information pertaining to the Commingled Funds to the IRS or other taxing authorities. Compliance with any new or revised laws or regulations could be difficult and expensive, and any uncertainty in respect of their implementation may result in increased taxes or other costs, reduced profit margins, and reduced investment and trading opportunities, and may require a significant restructuring of the manner in which the Commingled Funds are organized, all of which may negatively impact the performance of the Commingled Funds. It is possible that the U.S. federal income tax treatment currently accorded an investment in a Commingled Fund will be modified by legislative, administrative, or judicial action in the future. The nature  of changes in U.S. federal income tax law, if any, cannot be determined prior to enactment of any new tax legislation. However, such legislation could significantly alter the tax consequences and decrease the after-tax rate of return of investments in the Commingled Funds. Prospective investors therefore should seek, and must rely on, the advice of their own tax advisers with respect to the possible impact on their investments attributable to current legislation, as well as any future proposed tax legislation or administrative or judicial action. • Limited Regulatory Oversight—It is not expected that the Commingled Funds will be registered or required to register as investment companies under the U.S. Investment Company Act of 1940, as amended, (the “Investment Company Act”) in reliance upon an exemption available to privately offered investment companies. Thus, the provisions of the Investment Company Act intended to provide various protections to investors (which, among other things, require investment companies to have a majority of disinterested directors, provide limitations on leverage, limit transactions between investment companies and their affiliates, require securities of an investment company held in custody to be individually segregated at all times from the securities of any other person and marked to clearly identify such securities as the property of such investment company, and regulate the relationship between the adviser and the investment company) are not applicable. • Government Investigations—In the event that TPW, an Adviser, or any current or former principal, director, trustee, manager, member, partner, officer, employee, or affiliate thereof becomes the subject of (or is otherwise involved in) any formal or informal investigation by a governmental or regulatory agency or is otherwise suspected to have engaged in or be involved in any wrongdoing (including through reports in the press), such event may have a material adverse effect on the Commingled Funds, regardless of whether TPW, the Adviser, or such other person is ultimately charged or found to have engaged in any wrongdoing. Such investigation or suspicion may cause reputational and other harm to TPW or the Adviser (and, potentially, a Commingled Fund) and may dissuade new investors from investing with TPW or the Adviser, or may result in substantial redemptions from, the imposition of suspensions or other limitations on redemptions from, the liquidation of, or other consequences to the Commingled Fund. Item 9: Disciplinary Information Legal and Disciplinary TPW’s employees have not been involved in legal or disciplinary events, whether relating to the Firm’s operations or to past or present investment client relationships. TPW’s foreign affiliate and parent company, Banque Transatlantique, has been subject to a disciplinary event by its local regulator relating to its advisory business. TPW does not view this event as material to a client's evaluation of its advisory business or the integrity of its management. Additional information relating to the Banque Transatlantique disciplinary event can be found in Part 1 of TPW's Form ADV. Item 10: Other Financial Industry Activities and Affiliations Financial Industry Activities As stated throughout this Brochure, based on information about a client’s financial condition, investment objectives, investment risk profile and other factors that may be relevant to proposed investments to an advisory client, TPW will advise the client about the efficient allocation of assets in the client’s account to different forms of investments and investment management, including, without limitation, designation of other investment advisers, who will actually invest and reinvest assets on behalf of the client. TPW will typically receive its negotiated advisory fee from its advisory client, regardless of whether such fee  relates to the management of the account by TPW or to the monitoring of the sub-advisor’s discretionary portfolio management of the client account. TPW will monitor the performance of each sub-advisor as it manages that part of or all of a client’s allocated account. Such monitoring will include review to determine whether the account is being managed in accordance with the mandate of the client. TPW will also determine, prior to recommending a sub-advisor to a client, that the sub-adviser is properly licensed and/or registered (or proper notice filing has been made) in each jurisdiction where such licensing or registration as an investment adviser is required. Other Financial Industry Activities or Affiliations TPW monitors the performance of its advisory client’s Asset Allocation account after the initial Asset Allocation Plan is implemented and, if deemed appropriate, recommends modifications to the Plan. To provide immediate and thorough oversight of a client’s portfolio of investments, the Firm considers it essential to have access to each client’s account on a regular basis. Accordingly, TPW recommends custodians in the U.S. and Europe (described in Selecting Brokerage Firms), which the Firm believes would offer competitive services while facilitating the Firm’s need for direct and transparent monitoring of the advisory client’s account(s), and the means for TPW to be able to produce timely and in-depth reporting and analyses of its advisory client accounts. A description of these custodian relationships is provided further in Selecting Brokerage Firms. TPW does not render or charge for any services other than the advisory fee for the advisory services described herein. Affiliations and the Mitigation of Potential Conflicts of Interest TPW recommends that client assets are held in custody at either Interactive Brokers or Charles Schwab in the U.S., or its parent affiliate, Banque Transatlantique in France, in Luxembourg or in Belgium. Whichever custodian the client chooses, a custody fee can be charged. The custody fee is in addition to the advisory fee payable to TPW. TPW does not share or benefit in any from the custodial fees charged to the client. The custodians may also have distribution agreements with several other managers of hedge funds, mutual funds, and traditional asset portfolios managers, under which they act as placement agent or solicitor for the funds and receive remuneration for placing investors in those funds. Any such compensation of the custodian will be in addition to and separate and distinct from the advisory fees payable for investment advisory services to TPW. The Adviser does not share in or benefit from the fees earned by a custodian for client placement. Although TPW and its French custodian, Banque Transatlantique Paris, are affiliates (Banque Transatlantique Paris is the direct owner of TPW), which is in turn a subsidiary within the Credit Mutuel Alliance Federale group of companies domiciled in France and Europe (see Firm Description), TPW and the French custodian operations are operationally independent as that term is defined by SEC Rule 206(4)-2. In brief, TPW and the custodian are not under common supervision, they do not share employees, and do not share common space (TPW is in the USA, the custodian is in Europe). In addition, Client assets in the custody of the custodian would not be subject to claims of TPW's creditors, and TPW does not have custody, possession of, or direct or indirect access or control of the client assets held in custody beyond the Firm’s ability to deduct its advisory fees directly from the client account as authorized in the Advisory Agreement and subject to specific safeguards described in SEC Rule 206(4)-2. Accordingly, the management of the custodian acts independently from the management of TPW. Form ADV Part 1A Item 7A provides information about the various persons that are advisory affiliates (or those persons employed by or involved in the management or control of the Firm). In terms of the Firm’s related persons, which include the advisory affiliates and any other entities within the Credit Mutuel Alliance Federale group of companies under common control with TPW, which is a far more extensive list. Many of the entities in the Credit Mutuel Alliance Federale group of companies, although considered related entities, do not have any material connection to the business of TPW. Accordingly, only those entities that occupy  shared space or are instrumental in the business of the Firm are listed on Forms ADV Part 1 and here in Form ADV Part 2. As listed on Form ADV Part 1A Section 7.A. of Schedule D, TPW’s Financial Industry Affiliations are as follows: • Banque Transatlantique – Paris: is the parent company of TPW. It practices governance over the U.S. entity, TPW, and provides support services such as the availability of its custodial services division and the availability of its research capabilities with teams based throughout Europe; • Dubly Transatlantique Gestion: is a Paris-based adviser, which provides TPW support with its asset management modeling capabilities; • Banque Transatlantique Luxembourg: is based in Luxembourg, a member of the Credit Mutuel Alliance Federale group of companies, and provides custodial services to TPW’s clients. • CIC Market Solutions, Inc.: is a New York based MEMBER: FINRA/SIPC institutional broker dealer that maintains office space at CIC Credit Industriel et Commercial New York Branch. CIC Market Solutions office space is located in a separate area from TPW within the multi-floor offices of CIC Credit Industriel et Commercial New York Branch. TPW requires that Clients use the execution services offered by CIC Market Solutions for most European trades. For the avoidance of doubt, TPW places Client European trades with CIC Market Solutions, which executes such trades on behalf of Clients. In seeking best execution, the determinative factor is not just cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the broker’s services. Clients should understand that the appointment of CIC Market Solutions as their broker for European trades in their accounts may result in disadvantages to the Client as a possible result of less favorable executions than may be available through the use of a different or a wider range of broker-dealers. Not all advisers require their clients to direct brokerage. Although advisory affiliates of TPW, none of the above-named firms exert management control over the Firm, other than Banque Transatlantique’s board governance role. CIC Market Solutions, Inc. only shares a location with the Firm. It is entirely independent from TPW. In practice, the remaining parties provide services, of which TPW makes use. TPW is able to leverage the asset allocation modeling developed by Dubly Transatlantique Gestion, and the product of mutual fund analysis and recommendations developed by the Credit Mutuel Alliance Federale asset management teams based in Paris, Brussels, and Luxembourg. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics TPW has adopted a Code of Ethics, pursuant to Rule 204A-1 under the Investment Advisers Act of 1940, as amended, that reflects the Firm’s high standards and commercial honor for the conduct of its business and for the proper performance of its duties with respect to its clients. TPW’s Code of Ethics requires its personnel to conduct themselves at all times in compliance with the following standards of business conduct: • The Firm has a strict policy of complying with all applicable laws, rules and regulations, including but not limited to Federal Securities Laws. • As a fiduciary for its clients, it is the Firm’s policy to act in the interests of its clients and adhere to the highest ethical standards in its dealings with clients.  • The Firm and its Supervised Persons shall deal with all clients in the utmost good faith and shall disclose to clients all material facts relating to the advisory relationship. TPW will provide a copy of the Code of Ethics to a client or prospective client upon request. Participation or Interest in Client Transactions TPW has adopted a Code of Ethics that is designed to promote compliance with the relevant legal and fiduciary obligations to which TPW is subject, and is based upon the principle that the Firm and its Investment Adviser Representatives owe a fiduciary duty to TPW’s clients. In general, all persons subject to the Code of Ethics must conduct their affairs in such a manner as to minimize potential conflicts of interest and to avoid serving their personal interests ahead of clients; taking inappropriate advantage of their position with TPW; and any actual conflicts of interest or any abuse of their positions of trust and responsibility. In terms of TPW and the brokers it may use to facilitate securities transactions in a client’s account, whether by • placing the client in an affiliated fund; • placing the client in a fund or separate account managed by another unaffiliated investment advisor; or by • executing client account transactions in a brokerage account held at one of the recommended custodians Please review TPW’s policy regarding revenue generated by TPW or one of TPW’s recommended broker custodians for any such transactions as described above in the Affiliations and the Mitigation of Potential Conflicts of Interest section. Personal Trading The Chief Compliance Officer (“CCO”) of TPW is Mr. Xavier Volatier. The CCO, or their designee, reviews all employee personal transactions no less than quarterly in accordance with the Firm’s Code of Ethics; and his own personal securities transactions are reviewed by a senior compliance manager of the Firm’s parent affiliate, which is the sole member of the Firm acting in a governance role. The personal trading reviews ensure that the personal trading of all TPW supervised persons do not affect the markets and are in compliance with the Firm’s Code of Ethics. Item 12: Brokerage Practices Selecting Brokerage Firms TPW recommends to its advisory clients, whether U.S. persons or French persons, several different custodial arrangements, which the Firm believes meet its criteria for best execution, pricing, and critical access to portfolio information. Although each advisory client is free to choose where they will maintain a custody account relationship, TPW recommends these custody arrangements in order to facilitate TPW’s close monitoring of its advisory accounts. The Firm has arranged to have portfolio monitoring capabilities through each relationship, fund and investment analysis tools, and performance reporting facilities through these broker and custody arrangements that allows TPW to have more immediate and complete access to client account information. TPW recommends that Advisory clients, who are U.S. persons wishing to have their assets held in custody in the U.S., open their brokerage account with TPW’s strategic partner in the U.S., Interactive Brokers or Charles Schwab. Interactive Brokers and Charles Schwab have adopted a commission schedule that is competitive with the commission schedules of other introducing broker-dealers providing the same or similar  services to their customers. TPW does not receive any of the services noted above (portfolio monitoring capabilities; fund and investment analysis tools; and, performance reporting facilities) on a soft dollar basis, and does not pay higher commissions as a result of receiving these services. Although TPW cannot guarantee that its advisory clients will always pay lower fees on a given transaction executed at one of its recommended brokers, the Adviser believes that the competitive pricing arranged with its recommended brokers is well worth the value received from these brokers. Banque Transatlantique acts in the capacity of a custodian only, and does not engage in the execution of transactions or provide any brokerage services for TPW clients. By the same token, if a client determines that an account be held in custody at an alternative broker or custodian to which the Firm agrees, TPW cannot guarantee that the best execution received from that brokerage arrangement would be the best available, whether on an absolute or relative basis. The fees charged by the brokers and custodians executing brokerage transactions and providing custodial services are, as noted throughout this Brochure, separate and distinct from the TPW advisory fee charged to each advisory client. TPW believes these policies support the best interests of its advisory clients. Best Execution and Order Aggregation TPW maintains written policies and procedures regarding Best Execution it receives from the broker to which it submits client orders. Generally, TPW does not aggregate client orders, but maintains policies and procedures should it have a need to aggregate client orders in the future. The executing brokers utilized by TPW are also required to conduct best execution reviews of client transactions, and also must adhere to rules when aggregating orders; in accordance with regulatory requirements and their own written supervisory procedures. Soft Dollars TPW does not engage in soft dollar business activities. Item 13: Review of Accounts Periodic Reviews TPW provides account review services to its clients in the form of • portfolio manager and investment advisor evaluation and selection • portfolio manager monitoring; and • portfolio monitoring Under the direction of TPW’s CCO and Managing Director, Mr. Xavier Volatier, the Firm selects and monitors its portfolio manager universe through regular, ongoing analysis of each portfolio manager and management firm regarding portfolio composition and risk levels. Significant published news about a fund or manager raising a concern; variations in the performance and/or volatility of a fund or portfolio; or any other cause for concern in the opinion of the CCO can trigger heightened scrutiny by the CCO of a manager’s investment decision(s). Accordingly, closer scrutiny of a manager or fund could take place at any time in addition to regular reviews if such action is warranted by the facts and circumstance in the opinion of the CCO.  TPW also endeavors to conduct an annual full-scale due diligence review of each portfolio manager’s performance and overall record with an in person meeting where at all possible. Also, under the direction of the Firm’s senior management, the Firm provides to clients regular written portfolio monitoring (depending on the client’s needs and preferences). The Firm make sure each client receives a specific breakdown of assets under management in the form of a regular statement (at whatever frequency desired by the client, but no less than quarterly) that contains both combined asset monitoring of positions held at multiple funds and/or portfolio managers and performance monitoring. TPW’s separate account review process is also an exhaustive process driven by the Firm’s Risk Committee, which reviews new portfolio positions and reviews the results of the Firm’s quarterly review of Best Execution, Order Aggregation, and Performance. Nature and Frequency of Regular Reports to Clients The nature and frequency of regular reports to clients is highly flexible and tailored to each client’s needs and wishes. At least once each calendar quarter TPW will review either the client’s Asset Allocation Plan and the results of investments pursuant to that Plan or the performance of the separate account. Performance will be revealed in terms of: the performance of assets since the last statement • • performance since the opening of the account as well as on a current year-to- date basis TPW will request from each client in the monthly or quarterly review (or at least on an annual basis) any changes in the client’s personal investment information. Based on this review and all information supplied by the client, the Firm may recommend changes (or continuation) of the Asset Allocation Plan. Subject to the written instructions of the client, the Firm will assist each advisory client with the implementation of any changes in the Plan. Item 14: Client Referrals and Other Compensation TPW entered into arrangements providing for compensation by the Firm to third parties in exchange for referrals of prospective advisory clients who ultimately establish accounts with TPW. TPW and none of the referring parties are affiliated, and the referring parties are not authorized to provide investment advice on behalf TPW. The referral fees paid by TPW to the referring parties are not passed on to referred clients, but the presence of these arrangements may affect TPW willingness to negotiate below its standard investment advisory fees and therefore, may affect the overall fees paid by referred clients. Item 15: Custody Custodians and Account Statements All client account assets are held at qualified custodians. This means the custodians provide account statements directly to clients at their address of record at least quarterly. Clients are urged to compare the account statements received directly from their custodians to the statements provided to them by the executing broker or dealer. Every advisory client is urged to carefully review all statements received from their custodian to be sure the information is current, correct, and complete. As described more fully in Selecting Brokerage Firms (above), TPW recommends to its advisory clients, whether U.S. persons or those resident in Europe, two specific custodial arrangements, which the Firm believes meet its criteria for best execution, pricing, and critical access to portfolio information. Although each advisory client is free to choose where they will maintain a custody account relationship, TPW recommends these custody arrangements in order to facilitate TPW’s close monitoring of its advisory  accounts. The Firm has arranged to have portfolio monitoring capabilities through each relationship, fund and investment analysis tools, and performance reporting facilities through these broker and custody arrangements that allows TPW to have more immediate and complete access to client account information. TPW recommends that Advisory clients, who are U.S. persons wishing to have their assets held in custody in the U.S., open their brokerage account with TPW’s strategic partner in the U.S. Interactive Brokers and Charles Schwab. In the case of advisory clients that seek their assets to be held in custody in France, TPW can facilitate custody arrangements with the Firm’s parent company, Banque Transatlantique in Paris, France, which is regulated by the Autorite de Controle Prudentiel et Resolution ("ACPR"). Performance Reports and Net Worth or Value Statements Clients are urged to compare any performance reports, and net worth or value statements received directly from their custodians and/or broker or dealer to the reports provided to them by TPW. Item 16: Investment Discretion Discretionary Authority for Trading All prospective clients managed by TPW on a discretionary basis are provided with a discretionary investment advisory agreement prior to assuming such responsibility. The TPW’s advisory clients generally grant TPW full authority to select the securities to be purchased or sold and determine theirs amount. TPW exercise such discretion in a manner consistent with TPW investment objectives and advisory client account investment objectives, limitations and restrictions. Item 17: Voting Client Securities Proxy Votes TPW does not vote proxies relating to client accounts. The qualified custodian would provide all proxy materials to the client. Clients may certainly contact the Adviser to discuss their thinking and decision-making process in regard to proxy materials they are considering. Item 18: Financial Information Financial Condition TPW does not have any financial impairment that will preclude the Firm from meeting contractual commitments to its clients or other business parties. The Firm has not at any time been the subject of a bankruptcy petition, including the past ten years, disclose this fact, the date the petition was first brought, and the current status.