https://www.sec.gov/Archives/edgar/data/1261788/000089418923002318/bramshilltapinvestminimums.htm
497 1 bramshilltapinvestminimums.htm 497E
Trust for Advised Portfolios
Supplement dated March 30, 2023
to the Prospectus dated July 31, 2022
for the Bramshill Income Performance Fund
We are pleased to inform you that effective April 29, 2023, the initial investment minimum for the Institutional Class of the Bramshill Income Performance Fund (the “Fund”) will decrease from $100,000 to $1,000 and the subsequent investment minimum will decrease from $5,000 to $100.
Also effective April 29, 2023, the initial investment minimum for the Investor Class of the Fund will decrease from $1,000 to $100 and the subsequent investment minimum will decrease from $100 to no minimum.
Effective April 29, 2023, the following changes are made to the Fund’s Prospectus:
The table under “Purchase and Sale of Fund Shares” on page 7 of the Prospectus is replaced with the table below to reflect the new investment minimums:
Institutional Class Investor Class
Minimum Initial Investment
$1,000 $100
Minimum Subsequent Investment
$100 No Minimum
The first paragraph under “How to Buy Shares” on page 18 of the Prospectus is replaced with the paragraph below to reflect the new investment minimums:
The minimum initial investment amount for the Institutional Class shares is $1,000 and the minimum subsequent investment amount is $100. The minimum initial investment amount for the Investor Class shares is $100 and there is no minimum subsequent investment amount.

There were minor decreases in stock allocations & increases in m-mkt allocations. The changes for OEFs + ETFs were based on a total AUM of about $30.07 trillion in the previous month, so +/- 1% change was about +/- $300.7 billion. Also note that these changes were from both fund inflows/outflows & price changes. #Funds #OEFs #ETFs #ICI
OEFs & ETFs: Stocks 58.38%, Hybrids 5.21%, Bonds 19.89%, M-Mkt 16.52%
https://ybbpersonalfinance.proboards.com/thread/245/fund-allocations-cumulative-monthly?page=2&scrollTo=994

Honestly, I don’t get the feeling that we’re in a nasty bear market or that things will worsen a lot. Of course there will be a recession at some point. But I don’t think we’ll re-test the lows of 2022 - unless the economy really falls off a cliff. I get a better sense from watching the Dow which topped out around 37,000 in late ‘21 / early ‘22 and then fell to around 29,500 mid-year ‘22 as best I can determine. I think success going forward depends a lot on countries / geographic regions chosen. Some may get a boost (from currency) if dollar continues down. And also individual companies may be better bets than the total market if one is willing to take the risk of investing in individual stocks. (But it’s not a small risk.)
As the above demonstrates: “Any idiot can voice an opinion”. I’m not qualified to make such calls. Just saying how I try to position my own stuff.

T Rowe Price Article on the Secure Act 2.0:
troweprice.com/what-investors-need-to-know-about-secure-20-provisions

If there is any place where the vulnerabilities of the system to runs and fire sales have been clear-cut, it is money market funds.
...
Even without a fixed NAV, liquidity mismatch in other kinds of funds can still make them vulnerable to runs and fire sales.

Falling between the cracks here are floating NAV money market funds - neither fixed NAV nor other (non-MM) kind of fund. I suspect this was an unintended omission.
The alternative would be that she considers floating NAV MMFs to be relatively immune to runs and fire sales. That's not beyond the realm of possibility. The MMF runs she describes are due to funds breaking a buck and investors rushing for the gates (a la SVB, Reserve Fund) - first mover advantage.
Floating NAV MMFs by definition can't break a buck - they aren't fixed to a $1 nominal NAV. Redemption values vary continuously (fractions of a percent) rather than discretely (1%, a penny at a time).
FWIW, one can invest in floating NAV MMFs via Merrill. That's one of the very few advantages I can see in that brokerage, though one of which I'm not partaking.
Footnote 13 (in the OP) is a cite to https://www.sec.gov/news/press-release/2021-258
The proposed MMF rules she refers to would have removed redemption fees/gating, and imposed swing pricing on institutional funds. This 2021 proposal is still being worked on and seems to still be accepting comments (last one was Feb 2023).
Proposal: https://www.sec.gov/rules/proposed/2021/34-93784.pdf
Fact sheet: https://www.sec.gov/rules/proposed/2021/ic-34441-fact-sheet.pdf
Comments: https://www.sec.gov/comments/s7-22-21/s72221.htm
Mutual fund managers responded to the redemption fee/gating rules by managing the funds more conservatively so that the rules would never be triggered. They were concerned that if a fund got close to that point, investors would stampede out - first mover advantage redux.
Or something else might spook investors. Say, a pandemic.

Evidence indicates that SEC's reforms did not prevent runs during the COVID-19 pandemic. For example, prime MMFs—which can invest in all types of short-term debt instruments—held by institutional investors experienced net redemptions of about 30 percent of their total assets in a 2-week period in March 2020 (see figure). Some evidence also indicates SEC's reforms may have contributed to the runs. Some investors may have preemptively redeemed MMF shares to avoid incurring a liquidity fee or losing access to their funds under a redemption gate.

https://www.gao.gov/products/gao-23-105535
Notable in that report and in the SEC's proposal is the focus on institutional investors. (Swing pricing for institutional investors, relaxed restrictions on retail investors.) As with SVB, institutional investors are apparently the elephants in the room stomping on everyone else.

I saw that on Twitter. But +20% from the recent lows applies only to Nasdaq 100 QQQ/$NDX from the late-December lows, and not to Nasdaq Comp ONEQ/$COMPQ. Other major indexes had their lows in October and are still struggling.
Ed Yardeni, neither a perma-bull nor a perma-bear, now has 4,600 for SP500. I am watching 4,300-4,600 range myself to do some asset reallocations. https://ca.finance.yahoo.com/news/us-stocks-could-end-14-110609639.html

AAII Sentiment Survey, 3/29/23
For the week ending on 3/29/23, bearish remained the top sentiment (45.6%; very high) & bullish remained the bottom sentiment (22.5%; very low); neutral remained the middle sentiment (31.9%; about average); Bull-Bear Spread was -23.1% (very low). Investor concerns: Inflation (moderating but high); economy; the Fed; dollar; cryptos; market volatility (VIX, VXN, MOVE); Russia-Ukraine war (57+ weeks, 2/24/22- ); geopolitical. For the Survey week (Th-Wed), stocks were up, bonds down, oil up, gold up, dollar up. The US bank hearings provided insights into the crisis as the regulators watched. #AAII #Sentiment #Markets
https://ybbpersonalfinance.proboards.com/thread/141/aaii-sentiment-survey-weekly?page=9&scrollTo=993

I watch this one as one gage of how conservative allocation funds are faring. For years it’s been regarded (ISTM) as the Cadillac of that group.
Surprised to see it down 0.30% YTD even after today’s +.45% gain. And last year it lost more than 9%. Never owned it. Just trying to figure out what’s causing its problem - likely some staple in its mix that isn’t performing as expected.

LOL - Funny. To be honest, I did a little “pruning” today (sold a bit). But by no means is that a bearish call.
Oh. I wouldn’t worry about Schwab’s survival. But financials / brokerages can be a bumpy ride. TRP nose-dived about 50% last year if I remember correctly.

Be careful what you ask about. You might get more than you bargained for :-)
There were a couple of exceptions to the "usual" step up rule in the past, there's one current exception (in timing), and potentially one in the future. Perhaps others that I'm not aware of.

Step-up in basis has been eliminated twice during the past 50 years, and each time, the change was short-lived.
Step-up in basis was first eliminated by the Tax Reform Act of 1976 and replaced with a carryover basis regime. The carryover basis rules were heavily criticized and repealed a few years later, before they had taken effect.
The Economic Growth and Tax Relief Reconciliation Act of 2001 repealed the estate tax and adopted a carryover basis regime [no step up] for calendar year 2010 only ...
Congress eventually threw everyone a curveball. In mid-December [2010], Congress retroactively restored the estate tax and step-up in basis for 2010 decedents. However, for decedents who died in 2010, estate executors could opt out of the estate tax and into a carryover basis tax regime.

https://www.aperiogroup.com/blogs/repeal-of-basis-step-up-third-times-the-charm
The current estate tax law generally provides for a step up (or down) to current value as of date of death. However, for estates subject to the estate tax, an executor can elect to do an assessment of all assets in the estate (it's all or nothing) on the alternate valuation date six months after the date of death, assuming that would result in lower federal estate taxes.
The exception to this exception is if an asset is transferred (via sale, distribution, or other method) prior to the end of the six month period, the individual asset is valued as of the date of transfer.
Recent federal and state proposals are floating around to tax billionaires on unrealized capital gains annually based on mark-to-market valuations.
https://itep.org/president-bidens-proposed-billionaires-minimum-income-tax-would-ensure-the-wealthiest-pay-a-reasonable-amount-of-income-tax/
https://www.washingtonpost.com/business/2023/01/17/wealth-taxes-state-level/
Under these proposals there would be no need for a step up because assets would already be valued at their last annual market price. Further, often these proposals are limited to easily priced securities. They might treat real estate and securities differently.

just put in stop loss on SCHW at $50

I would assume if they are audited the IRS will want receipts, ie that $5000 check for the fence!
Tell them to be glad their house value went up . We lost money on the sale of our house in CT over 30 years

Just bought 10k SCHW. Already ahead $4.57! A winner, at last !!!

Another possibility for a "safe harbor" option, if someone is etf savvy is the treasury floating rate ETF, USFR paying 4.79% now. It is all treasury bills with a duration 0f 0.02. In addition it is state tax free with 100% t-bills. This has worked well for me in this rising interest time but it can be bought and sold anytime without cost in most brokerages. I also own t-bills but USFR is hassle free if you do not wish to constantly roll over the t-bills on your own. I do not use the Fidelity rollover program because I prefer to be able to change each duration if appropriate when each matures and of course you do not pay the 0.15 ER of USFR in buying the t-bills themselves.

I'm not bothered at all by the extra coverage some uninsured depositors received at SVB. I'm just glad the FDIC agrees to guarantee deposits up to $250,000. Some libertarians want to go back to pre-1933 and eliminate FDIC guarantees for any amount. OH hell no !

Half of the deposits that remained post seizure have already flown the coup:
$119B in Silicon Valley Bridge Bank deposits on March 10th.
$56B in deposits transferred (sold) to First CItizens
-----
$63B in deposits pulled out of the bridge bank.
https://finance.yahoo.com/news/silicon-valley-bank-rapid-withdrawals-100029288.html ($119B)
https://www.reuters.com/markets/deals/first-citizens-said-be-near-deal-silicon-valley-bank-bloomberg-news-2023-03-26/ ($56B)
There's always a risk of failure. Just as we saw a move to government MMFs after Reserve Fund broke a buck, some large depositors have wised up to the fact that uninsured really means "at risk". Even though the Treasury provided temporary insurance after Reserve Fund failed and even after the FDIC covered all depositors at SVB.

ssue not easily dismissed by red herring arguments. Of course other instances of injustice have existed throughout history. Doesn’t in any way explain or justify this instance.
I think you missed my point. Depositors who get "only" $250K of insurance are not being cheated. They are getting their fair share of coverage. It's the fact that someone else is receiving extra that's the red herring. Sure you're envious, sure you think they shouldn't have gotten that extra coverage, but that's got nothing to do with how much coverage you fairly deserve - $250K.
My insurer decides to cover neighbor’s loss. Says it will recoup its expenses by raising my insurance rates and those of other paying customers.
You bring up cost, suggesting that this windfall (SVB depositor unlimited coverage) to others is costing you money. As has been recently pointed out, the FDIC bailout will be paid for by other banks, not by taxpayers. So the broad populace isn't bearing the insurance cost.
What about the costs you bear indirectly as a customer of a bank being assessed for this bailout? In 1993 the FDIC changed the way it charged banks for coverage - the more risky the bank, the more they were charged (risk-based premiums). So some of this is already built into the system. And unlike the auto insurance example that's based by neighborhood, this premium discrimination appears to be done bank by bank.
From what OJ posted at the top, it looks like the cost of the bailout might also be apportioned among banks according to the risks they pose. IMHO that would be a good idea.
Finally, in your example, your neighbor was uninsured, rather than underinsured. There's a red herring FDIC does not bail out non-member banks. Those banks don't pose systemic risks because depositors at FDIC member banks will not start pulling money out upon seeing a non-member bank failing.

it was clear to the "market" (but not to regulators?) that IF the HTM Treasuries were marked-to-market, the equity (the book values) of the failed banks would have been wiped out.
What does "clear to the 'market'" mean? Are we talking about the magnitude of the risk of being wiped out by a run? Wouldn't the market incorporate clearly perceived risk into an equity's price?
If stock price is a metric of risk perception, it looks like the risk wasn't clear to the market until after SVB virtually failed. On March 8, SVB announced to the world that during the day it had run out of AFS securities and needed to raise cash immediately.
The March 8th closing price of SIVB was $267.83, with volume in its typical range of well under 1M shares traded. The price was up 16% YTD. The next day trading volume exceeded 38M shares and the price dropped 60% while the market was open. It dropped further after the market closed before trading was halted.
https://finance.yahoo.com/quote/SIVB/history?p=SIVB
https://news.yahoo.com/svb-shares-slump-again-clients-105042807.html
Technically there are only two failed US banks, SVB and Signature. Admittedly, Republic Bank would have failed without extraordinary measures.
https://www.fdic.gov/bank/historical/bank/bfb2023.html
Signature Bank was different from SVB, because its involvement in cryptocurrency did make its risk apparent after SVB's collapse. Barron's wrote:

Signature also had a cryptocurrency business. While Signature didn't have loans backed by cryptocurrencies or hold cryptocurrencies on its balance sheet, it had a payment platform for processing crypto transactions. But deposits associated with the crypto platform had been dropping, prompting some concern from Wall Street.
Before SVB's failure, there wasn't too much concern. Signature had 10 Buy ratings out of 17 analysts listed on Bloomberg following earnings reported on Jan. 17. The average analyst price target was about $145 a share.
As the crisis at SVB mounted, Signature stock fell about 50%. The company reported deposit balances of about $89 billion and loan balances of about $72 billion on March 8.

https://www.barrons.com/articles/signature-bank-shut-down-collapse-a0adf63f
So far, I haven't found a report that Signature's security portfolio was loaded with Treasuries (not that I've looked that hard). As you noted, all types of long term securities are subject to interest rate risk - not just Treasuries, and not just illiquid securities. It would be interesting to know, strictly as a matter of curiosity, what Signature was holding.

House sale and capital improvements to calculate capital gains on sale question.
So, house purchased for 'x' $ 20 years ago.
There is a capital gain on the sale of the property, which will be taxable.
Improvements to the property may be used to change the 'cost basis' for calculating full capital gains tax.
My question (below) is that it was stated that the owners made numerous improvements to the property over the years; which did provide for a higher sales price.
One example is, a very nice fence that was placed around the property that cost $5,000 15 years ago, but would cost $15,000 to build today.
The seller, of course, wants to keep the capital gains tax on the sale as low as possible.
It is my understanding that they may use the original $5,000 to change the 'cost basis'; whereas it is suggested they may use the $15,000 cost (when the house was sold), if the fence was installed today, to calculate the 'cost basis'.
In effect, they are suggesting using an 'inflation adjusted' value.
Is this allowed in the IRS tax code for calculating a property sale 'cost basis' to establish the capital gains amount???
Thank you for your time in sorting this conflict of thought about this process.
Catch

There is lot of negative news on the CRE exposures of smaller banks. The 3 US bank failures so far had high exposures to US Treasuries (HTM*, AFS*) and had industry concentrations in tech (private-equity, venture-capital) and cryptos. No US bank has failed yet for the CRE exposure, but if that happens, that may be the max negativity for CREs. Affected may be quarterly-liquid (TIAA) T-REA and illiquid/nontraded-REITs - BREIT, SREIT (typical limits 2% per month, 5% per quarter), etc.
Story is similar. The HTM portfolio is NOT marked-to-market. While that is "legal" and "allowed" by the accounting rules, it was clear to the "market" (but not to regulators?) that IF the HTM Treasuries were marked-to-market, the equity (the book values) of the failed banks would have been wiped out. When the bank runs happened, the HTM and AWS distinction basically disappeared. In the CREs, the revaluations are slow (e.g. T-REA), or not even done (some nontraded-REITs).
Another concern is that the HTM and AWS practices are also found among insurance/annuity companies and pension funds, not just among banks, credit unions, brokerages.
*HTM - Hold-to-maturity (these are not marked-to-market), AWS - Available-for-sale (these are marked-to-market)