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A. T2 Asset Management, LLC
T2 Asset Management, LLC (“T2 Asset Management” or the “firm”) is a registered investment
adviser. The firm is organized as an Illinois limited liability company providing Investment
Management, Wealth Planning, and Business Advisory Services to individuals and institutions. T2
Asset Management was formed in May of 2013. The firm is principally owned by Kenneth (“Ken”)
S. Tomko.
B. Advisory Services Offered
T2 Asset Management is an independent asset management and financial planning firm offering
a variety of financial services to individuals, trusts, corporations, partnerships, retirement plans,
tax exempt and other legal entities.
All of our strategies provide diversified, multi-asset class exposure in separately managed
accounts based on the client’s investment objectives. The firm’s clients have the ability to
impose reasonable restrictions on our portfolio management.
T2 Asset Management tailors all services to the individual investment needs of its clients by
determining each client’s specific goals, objectives, risk tolerance, time horizon, investment
restrictions and other factors that might affect the client’s investment needs. Based on this
determination, the firm designs and implements an asset allocation framework geared toward
achieving the defined objectives. Based on our discussion with clients, we will suggest a
portfolio to the client that meets their risk tolerance and investment objective.
T2 Asset Management uses proprietary models to help guide our investment decisions and
attempt to manage portfolio risk. We offer our investment strategies in four (4) general models
depending on the risk tolerance of each client:
▪ Capital Preservation
▪ Growth and Income
▪ Growth
▪ Aggressive Growth
B.1. Investment Management Services
T2 Asset Management’s Investment Management Services include the following:
▪ Portfolio evaluation
▪ Assessment of investment objectives and financial goals
▪ Strategic asset allocation planning
▪ Security selection and trading
▪ Portfolio management and monitoring
▪ Performance measurement
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For its discretionary Investment Management Services, T2 Asset Management receives a limited
power of attorney to effect securities transactions on behalf of its clients that include securities
and strategies described in Item 8 of this brochure.
T2 Asset Management’s Investment Management Services are predicated on the client's
investment objectives, goals, tolerance for risk, and other personal and financial circumstances.
T2 Asset Management will analyze each client's current investments, investment objectives,
goals, age, time horizon, financial circumstances, investment experience, investment restrictions
and limitations, and risk tolerance and implement a portfolio consistent with such investment
objectives, goals, risk tolerance and related financial circumstances T2 Asset Management’s
objective is to review the client’s tax, financial, and estate planning objectives and goals in
connection with the client’s investment objectives, goals, tolerance for risk, and other personal
and financial circumstances and make appropriate recommendations and implementation
decisions. T2 Asset Management may engage third-party service providers to assist with the tax
and estate planning portion of the services provided to clients. In addition, T2 Asset
Management may utilize third-party software to analyze individual security holdings and
separate account managers utilized within the client’s portfolio.
In addition to providing T2 Asset Management with information regarding their personal
financial
circumstances, investment objectives and tolerance for risk, clients have the right to
provide the firm with any reasonable investment restrictions that should be imposed on the
management of their portfolio, and to promptly notify the firm in writing of any changes in such
restrictions or in the client's personal financial circumstances, investment objectives, goals and
tolerance for risk. T2 Asset Management’s annual Privacy Policy notice will remind clients of their
obligation to inform the firm of any such changes or any restrictions that should be imposed on
the management of the client’s account.
B.2 Retirement Plan Participant Account Management (Discretionary)
We use a third-party platform (Pontera Order Management System) to facilitate management of
held away assets such as defined contribution plan participant accounts, with discretion.
The platform allows us to avoid being considered to have custody of client funds since we do
not have direct access to client log-in credentials to effect trades. We are not affiliated with the
platform in any way and receive no compensation from them for using their platform. A link will
be provided to the client allowing them to connect an account(s) to the platform. Once client
account(s) is connected to the platform, we will review the current account allocations. When
deemed necessary, we will rebalance the account considering client investment goals and risk
tolerance, and any change in allocations will consider current economic and market trends. The
goal is to improve account performance over time, minimize loss during difficult markets, and
manage internal fees that harm account performance. Client account(s) will be reviewed at least
quarterly and allocation changes will be made as deemed necessary.
We may provide these services or, alternatively, may arrange for the Plan’s other providers to
offer these services, as agreed upon between our firm and the client.
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B.3. Wealth Planning Services
T2 Asset Management’s Wealth Planning Services include the following:
▪ Net worth analysis
▪ Liquidity and liability management
▪ Compensation and benefits analysis
▪ Retirement planning
▪ Education planning
▪ Philanthropy and charitable gift planning
B.4. Business Advisory Services
T2 Asset Management’s Business Advisory Services include the following:
▪ Business Advisory Services
▪ Retirement planning
▪ Risk management services
▪ Group benefit services
B.5. 401(k) Consultative Services
Upon completing a questionnaire provided by the firm, T2 Asset Management will provide a
one-time review of the performance of the client’s 401(k) account and provide the client with a
report of the firm’s investment advice, including allocation advice, regarding the investment
alternatives offered by the plan in accordance with the client's risk tolerance and investment
goals as set forth in the questionnaire.
C. Client-Tailored Services and Client-Imposed Restrictions
Each client’s account will be managed on the basis of the client’s financial situation and
investment objectives and in accordance with any reasonable restrictions imposed by the client
on the management of the account—for example, restricting the type or amount of security to
be purchased in the portfolio.
D. Wrap Fee Programs
T2 Asset Management does not participate in wrap fee programs. (Wrap fee programs offer
services for one all-inclusive fee.)
E. Client Assets Under Management
As of December 31, 2023, T2 Asset Management managed $140,000,000 of client assets on a
discretionary basis.
Item 5: Fees and Compensation