# TCM

> TCM is an SEC-registered investment advisory firm in Germantown, TN, registered since 2017, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated March 31, 2026.

- CRD: 289583
- Legal name: Trinity Capital Management, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Germantown, TN
- Filing period: October 2026
- Form ADV filing dated: March 31, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/289583
- AdvisorCensus page: https://advisorcensus.com/firm/tcm-germantown-tn-289583

## Quick answers

**How is TCM compensated?**
On its Form ADV (Item 5.E, October 2026), TCM reports these compensation arrangements: a percentage of assets under its management; hourly charges; fixed fees (other than subscription fees); other.

**How much does TCM charge?**
Its Form ADV Part 2A brochure dated March 31, 2026 states: Hourly rate: $500 an hour (financial planning services). Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Where is TCM located?**
TCM's principal office is in Germantown, TN, according to its Form ADV.

**Is TCM registered with the SEC or a state?**
TCM is an SEC-registered investment advisory firm, registered since 2017. Status as filed: Approved. CRD 289583.

**How much does TCM manage?**
TCM reports $164,518,086 in regulatory assets under management in its Form ADV filing dated March 31, 2026 (100% discretionary).

**How have TCM's assets and staff changed since 2021?**
In the Form ADV data for TCM: Regulatory assets under management: $110,561,154 in the October 2021 data and $164,518,086 in the October 2026 data, up 49%. Total employees: 4 in October 2021 and 5 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does TCM serve?**
By number of clients on Form ADV Item 5.D: individuals (other than high net worth individuals) (400); high net worth individuals (95); corporations or other businesses not listed above (1).

**Which custodians does TCM use?**
TCM's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Raymond James Financial Services, Inc. as a custodian holding 10% or more of its separately managed account assets.

**Does TCM report any disciplinary disclosures?**
Reports no disclosure items on Form ADV Item 11. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/289583

**Does TCM state an account minimum?**
Its Form ADV Part 2A brochure dated March 31, 2026 says: "In general, we require a minimum of $250,000 to establish a managed account. However, in our sole discretion we may accept clients that do not meet our minimum account requirements."

**What changed in TCM's recent Form ADV filings?**
In the April 2026 filing data: Regulatory assets under management went from $144,796,236 to $164,518,086 (+14%).

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Hourly charges
- Fixed fees (other than subscription fees)
- Other

### Fees and minimums (Form ADV Part 2A brochure dated March 31, 2026)

- Account minimum: $250,000 (the brochure says it may be waived or negotiated)

> In general, we require a minimum of $250,000 to establish a managed account. However, in our sole discretion we may accept clients that do not meet our minimum account requirements.

- Hourly rate: $500 an hour (financial planning services)

> $500 / hour (minimum two hours)

As stated in the firm's brochure. Fees can differ by service and may be negotiable.

### Custodians (Schedule D, Section 5.K(3))
- Raymond James Financial Services, Inc.

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

### Regulatory assets under management (Item 5.F)
- Total: $164,518,086
- Discretionary: $164,216,366
- Non-discretionary: $301,720

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 400 | $128,324,083 |
| High net worth individuals | 95 | $35,902,203 |
| Corporations or other businesses not listed above | 1 | $291,800 |

### Advisory services (Item 5.G)
- Financial planning services
- Portfolio management for individuals and/or small businesses
- Selection of other advisers (including private fund managers)
- Educational seminars/workshops
- Other

### Firm details
- Registered since: 2017 (9 years)
- Employees: 5 total, 2 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: AR, GA, LA, MS, TN, TX
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- trinitycapitalmanagement.net
- Facebook @TRINITYCAPITALMANAGEMENT
- X @MORRISNUTT_TCM

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $110,561,154 | 4 | March 16, 2021 |
| October 2022 | $119,434,916 | 4 | June 17, 2022 |
| October 2023 | $102,506,463 | 4 | March 23, 2023 |
| October 2024 | $114,326,100 | 5 | April 25, 2024 |
| October 2025 | $144,796,236 | 4 | March 28, 2025 |
| October 2026 | $164,518,086 | 5 | March 31, 2026 |

Regulatory assets under management: $110,561,154 in the October 2021 data and $164,518,086 in the October 2026 data, up 49%.
Total employees: 4 in October 2021 and 5 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Regulatory assets under management went from $144,796,236 to $164,518,086 (+14%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. TCM (CRD 289583): Form ADV filing data as of October 2026.