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

I know many folks cannot afford a subscription to Bloomberg News ( ? $300 a year) but I have found many of the columnists at least as useful as those in Barron's
Money Stuff by Matt Levine is extremely good at explaining very complicate financial and legal nuances, plus he pokes fun at himself!
Programming note: Money Stuff will be off tomorrow and next week, back on April 10. Empirically this is expected to dampen market volatility, though this is not investing advice and past results may not be representative of future performance. But enjoy a nice quiet week in financial markets without me, have fun, try not to break anything.

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.

"The structural vulnerabilities at the heart of money market and open-end funds aren’t new. In the banking sector, capital and liquidity requirements and federal deposit insurance reduce the likelihood of runs taking place. In case runs occur, access to the discount window helps provide buffers for banks. Yet the financial stability risks posed by money market and open-end funds have not been sufficiently addressed.
Over the past two years, the SEC has proposed rules to mitigate the vulnerabilities plaguing these funds.13 The SEC’s proposals would reduce the first-mover advantage, reducing run incentives during times of stress. They would also require new liquidity management tools, while mandating more comprehensive and timely information on these funds for the SEC and investors."
https://home.treasury.gov/news/press-releases/jy1376

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

Everything lost money last year, as you noted. VWINX was in the top decile in 2022.
https://www.morningstar.com/funds/xnas/vwinx/performance
Not so great YTD. At least part of that is due to its mandate - generate income. On the equity side, it invests in high dividend stocks. Vanguard is clear about this. The equity side of its benchmark is the FTSE High Dividend Yield Index.
https://investor.vanguard.com/investment-products/mutual-funds/profile/vwinx
VHYAX tracks this index. YTD it is down 4.26% vs. 1.99% for its category. While VWINX is actively managed, it swims in a pool that is underperforming this year. How have other high dividend equity funds done?
https://www.morningstar.com/funds/xnas/vhyax/performance

+1

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.

+1

It's a variant of TBTF bailouts. If the bank's insolvency doesn't rock the boat, it goes under. But if it is large enough to affect the financial structure .... A variant of the aphorism:

If you owe the bank $100 that's your problem. If you owe the bank $100 million, that's the bank's problem.

https://www.brainyquote.com/quotes/j_paul_getty_129274

+1 old joe excellent synopsis of the situation!

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

There was only 1 type of m-mkt fund during the GFC 2008.
The Fed then started unlimited insurance for m-mkt funds for 10 bps fees from 2008-10. After some resistance from big players, all complied.
From the lessons learned, m-mkt reforms of 2014/16 created 3 tiers of m-mkt funds - government, prime-retail, prime-institutional.
Huge shift into the government m-mkt followed.
But that was so huge that it may have damaged the commercial paper market.
So, the m-mkt reforms are being looked again - so soon.

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.