BLAIR HALL ADVISORS, LLC

Item 1: Cover Page Part 2A of Form ADV: Firm Brochure September 25, 2025 117 18th Ave East Seattle, WA 98112 www.BlairHallAdvisors.com Firm Contact: Thomas Gerson Chief Compliance Officer This brochure provides information about the qualifications and business practices of Blair Hall Advisors, LLC. If clients have any questions about the contents of this brochure, please contact us at (206) 397-0325 (or (212) 401-6924) or email info@blairhalladvisors.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any State Securities Authority. Additional information about our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #170114. Please note that the use of the term “registered investment adviser” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise clients for more information on the qualifications of our firm and our employees.  Item 2: Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update Blair Hall Advisors, LLC is required to notify clients of any material changes since the last annual update of the Firm Brochure (“Brochure”). Since the Firm’s last annual amendment filed on February 10, 2025, it has added a provision for Non- Exclusive Minimum Fees for new clients who do not maintain a minimum of 90% of their assets under management with the Firm to address the additional cost and complexity of providing service to those clients under those circumstances. The Firm has also changed the timeframe for reviews of accounts with balances below $250,000 for new clients. More information on these changes is available below in Items 4, 5, 7, and 13. Full Brochure Available Whenever you would like to receive a complete copy of our Firm Brochure, please contact us by telephone at: (206) 397-0325 (or (212) 401-6924) or email info@blairhalladvisors.com. ADV Part 2A – Firm Brochure Page 2 Blair Hall Advisors, LLC  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 & Compensation ................................................................................................................. 8 Item 6: Performance-Based Fees & Side-By-Side Management ..................................................... 13 Item 7: Types of Clients & Account Requirements ........................................................................... 13 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss .............................................. 13 Item 9: Disciplinary Information ......................................................................................................... 16 Item 10: Other Financial Industry Activities & Affiliations ............................................................ 16 Item 11: Code of Ethics, Participation or Interest in ........................................................................ 16 Item 12: Brokerage Practices ............................................................................................................... 17 Item 13: Review of Accounts or Financial Plans ............................................................................... 20 Item 14: Client Referrals & Other Compensation ............................................................................. 20 Item 15: Custody ...................................................................................................................................... 20 Item 16: Investment Discretion............................................................................................................ 21 Item 17: Voting Client Securities .......................................................................................................... 21 Item 18: Financial Information ............................................................................................................ 21 ADV Part 2A – Firm Brochure Page 3 Blair Hall Advisors, LLC  Item 4: Advisory Business Our firm provides individuals and other types of clients with a wide array of investment advisory services. Our firm is a Delaware limited liability company established in 2013 and registered as an investment adviser since August 2014. Our firm is owned primarily by Thomas Gerson, with Shelly Gerson (who is not a financial advisor) owning a minority interest. The purpose of this Brochure is to disclose the conflicts of interest associated with the investment transactions, compensation and any other matters related to investment decisions made by our firm or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is accomplished in part by knowing our client. Our firm has established a service-oriented advisory practice with open lines of communication for many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to understand their investment objectives while educating them about our process, facilitates the kind of working relationship we value. Types of Advisory Services Offered The Firm has Legacy Clients who receive services no longer on offer by the Firm. Comprehensive Portfolio Management: Our Comprehensive Portfolio Management service encompasses asset management as well as providing financial planning/financial consulting to clients. It is designed to assist clients in meeting their financial goals using financial investments. We conduct at least one, but sometimes more than one meeting (in person, if possible, otherwise via telephone conference) with clients to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we will propose an investment approach to the client. We may propose an investment portfolio, consisting of exchange traded funds, mutual funds, individual stocks or bonds, or other securities. Upon the client’s agreement to the proposed investment plan, we work with the client to establish or transfer investment accounts so that we can manage the client’s portfolio. Once the relevant accounts are under our management, we review such accounts on a regular basis and at least quarterly. We may periodically rebalance client accounts under our management. If the client experiences any significant changes to his/her financial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. We have no obligation to consider those changes in financial or personal circumstances until we are made aware of them. We will follow the guidelines on the approach to risk and to various asset classes as set forth in an “investment policy statement,” if we have one in place; until then, or if none is put in place, we will manage your investments using our good judgment and our firm’s documented understanding of your situation, which includes the information gathered in our initial discovery process as described above and during our annual meetings with you. (You will let us know if you wish to put an investment policy in place; or if we feel it is needed for your situation, we may initiate an effort to establish an investment policy.) Investments may include alternative investments, such as hedge funds, funds of hedge funds, private equity, funds of private equity or to the use of so-called “managed accounts” or “sub-advised” accounts, wherein a third-party advisor may assist with a portion of a client’s investments. We are accountable for ascertaining and monitoring the suitability of any such investments. Any third-party costs involved in these investments would be the responsibility of the client, separate from our fee. ADV Part 2A – Firm Brochure Page 4 Blair Hall Advisors, LLC  Such costs may or may not be deducted by the third-party directly from the investment itself, depending on the investment’s composition and legal structure. It is possible we may need to collect such third-party costs from a client on a pass-through basis, or that we may offer to do so as a service to our client. In no event would such costs ever be “marked up” by us and become a source of financial benefit for us. We review accounts on at least a quarterly basis. The nature of these reviews is to learn whether the client’s accounts are in line with their investment objectives, appropriately positioned based on our understanding of market conditions, and investment policies, if applicable. Only our Partners, Financial Advisors or Portfolio Managers will conduct reviews. We may review client accounts more frequently than described above at our discretion or upon client request. We do not provide written reports to clients, unless asked to do so or we feel that doing so will aid in discussions concerning decisions that need to be made. Oral reports to clients take place on at least an annual basis for clients who are responsive to our request for such a meeting or phone call. We ask clients to provide information or documentation pertaining to income, investments, taxes, insurance, estate plan, family obligations, or anything that would reasonably be deemed important to their financial situation. We expect them to be forthcoming and proactively share such important information with us. We also discuss with clients their investment objectives, needs and goals in an effort to stay informed of any changes. We need diligent participation from clients to adequately perform our services. We cannot verify any information obtained from you, your attorney, accountant or other professionals, and we rely on any information they provide. If a client requests and participates in the process, we will facilitate and provide formal (written) financial modeling and/or planning (hereinafter, “modeling and planning” or just “planning”) as often as once every two years if (i) your Assets with us are $5 million or more, (ii) we manage at least eighty percent of your investment assets, and (iii) certain other conditions are met. Under these conditions, the fee for the first twenty (20) hours of this planning shall be deferred until the end of the twelfth month following provision of planning services and, if such payment does not become due by such date, it shall be waived. Fees for effort exceeding twenty (20) hours are not deferred. If a client ceases to remain a client for such twelve-month period, this deferred fee shall become due and shall not be waived. The topics that are generally addressed in written planning include: Retirement Planning Our retirement planning services typically include projections of your likelihood of achieving your financial goals, typically focusing on financial independence as the primary objective. For situations where projections show less than the desired results, we may make recommendations, including those that may impact the original projections by adjusting certain variables (e.g., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years. Employee Benefits Optimization We will review and analyze whether you, as an employee, are taking appropriate advantage of your employee benefits and may recommend adjustments. If you are a business owner, we ADV Part 2A – Firm Brochure Page 5 Blair Hall Advisors, LLC  will provide guidance on the various benefit programs that can be structured to meet both business and personal retirement goals. Cash Flow and Debt Management We will review your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts. College Savings Includes projecting the amount that will be needed to achieve college or other post-secondary education funding goals, along with advice on ways for you to save the desired amount. Recommendations as to savings strategies are included, and, if needed, we will review your financial picture as it relates to eligibility for financial aid or the best way to contribute to grandchildren (if appropriate). (Disclosure: our expertise in financial aid is limited; the rules are constantly changing, and most of our clients are not eligible so we do not stay current on all possible financial aid details.) Financial Goals We will help clients identify financial goals and develop a plan to help maximize the possibility of reaching them. We will identify what you plan to accomplish, what resources you will need to make it happen, how much time you will need to reach the goal, and how much you should budget for your goal. Insurance Review of existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile. Investment Analysis This may involve developing an asset allocation strategy to meet a client’s financial goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee stock options, as well as assisting you in establishing your own investment account at a selected broker/dealer or custodian. The strategies and types of investments we may recommend are further discussed in Item 8 of our ADV 2A disclosure document. Risk Management A risk management review includes an analysis of your exposure to major risks that could have a significant adverse impact on your financial picture, such as premature death, disability, property and casualty losses, or the need for long-term care planning. Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance (“self-insuring”). Tax Planning Strategies Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, we may make recommendations on which type of account(s) or specific investments should be owned based in part on their “tax ADV Part 2A – Firm Brochure Page 6 Blair Hall Advisors, LLC  efficiency,” with consideration that there is always a possibility of future changes to federal, state or local tax laws and rates that may impact your situation. In the interests of best serving clients and keeping planning complexity “moderate” instead of greater (i.e., to avoid or minimize incremental cost to clients), we may prioritize the topics of greatest importance to a client’s situation rather than addressing every topic in every plan. Twenty hours, the amount of planning the fee for which can become eligible for deferral as described in more detail below, may not be sufficient to complete a worthwhile plan for every client. Nonetheless, we will proceed to completion unless clients initiate a request for a phased approach at the start of planning. It should be noted that pausing at phases can add time and cost overall. We complete plans once clients have responded to all our initial information requests unless a client instructs us to stop, or our relationship terminates, part way through. Unless otherwise arranged, we will aim to keep all plans at “moderate” complexity relative to clients’ situations. “Moderate” is defined at our discretion. We rely on planning software, and our planning may be susceptible to possible issues with data entry, software bugs, errors in our use of the software and all typical types of errors involved in using software, generally, even though we will make workmanlike efforts to avoid such errors. Planning a client’s finances years in advance is an uncertain process, and you understand that our planning results should be relied upon only as one point of view in your overall financial decision-making. If a client’s Assets with us are at least $3 million but less than $5 million, we will provide the above financial planning service up to once every three years. Informal discussions about a client’s financial plans and goals are always an included service, at all asset levels, at all times. In all instances, planning will be charged in full based on our hourly rate if a client ceases to be a client within twelve months of any planning activity, whether partial effort or completed, payable within 30 days or debited against any pro-rata refund due, or a combination. The start of any planning will be subject to resource availability. We may perform formal planning for clients more frequently than discussed above if requested and as resources are available, but without the benefit of any deferred and potentially waived costs. Supplemental charges may apply for written planning for assets held away, real estate investment assets, added complexity, and as otherwise detailed in client agreements. Depending on resource availability, planning at a greater frequency may be available for an additional fee. Client agreements govern details. We reserve the right to waive minimum account sizes and minimum fees and to offer fee discounts in our sole discretion and to negotiate the provision of more limited services in those scenarios. Tailoring of Advisory Services Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Participation in Wrap Fee Programs Our firm does not offer or sponsor a wrap fee program. Regulatory Assets Under Management ADV Part 2A – Firm Brochure Page 7 Blair Hall Advisors, LLC  As of December 31, 2024, our firm had $106,907,590 in assets under discretionary management. Item 5: Fees & Compensation Compensation for Our Advisory Services The Firm has Legacy Clients who receive services under agreements with fees no longer on offer by the Firm. Comprehensive Portfolio Management, Percentage of Assets Charged: Unless otherwise agreed on with you, on an annualized basis, our firm’s fees for our Comprehensive Portfolio Management service are as follows: Annual Fee As % of Assets Annual Percentage of Assets Charge 1.50% 1.00% 0.75% Assets Under Management Up to $1,000,000.00 Additional Amounts from: $1,000,000.01 to $10,000,000.00 Additional Amounts: Above $10,000,000.00 Our firm’s fees are billed on a pro-rata annualized basis quarterly in advance based on the value of a client’s account on the last day of the previous quarter as determined by an independent qualified custodian. For the first period of time that an account exists, which is almost always a fraction of a calendar quarter, that time period will be billed retroactively rather than in advance, using the account value from when an account is first fully funded, or using the account value from the end of the quarter in which the account is fully funded, at our discretion, and prorated based upon the number of days in that first period of time. The start date is determined as follows: i. ii. If an account is established as part of our initial working relationship, the date the client enters into a Master Services Agreement with us is used as the start date or a later date, at our discretion. If an account is established to be under our management subsequent to the starting period of our working relationship, the start date for that account is the date that the paperwork is signed that notifies the custodian of our authority. If such an account is not with our custodian, we shall use the date that you granted us authority in any written means, which may be by email, or a later date, at our discretion. Please note that clients may not assign accounts to our authority before an agreement is executed. If a client inadvertently does assign accounts to us too soon, fees shall not begin before a contract is executed. Our firm’s fees will be automatically deducted from client’s managed account(s) held by custodians with whom we have a direct relationship. Direct billing will only be available for accounts that are held by custodians that do not permit deductions. For avoidance of doubt, margin balances are disregarded. ADV Part 2A – Firm Brochure Page 8 Blair Hall Advisors, LLC  If at any point we manage accounts where direct billing is necessary, invoices will be sent via email only (subject to an email opt-out provision, detailed in client agreements). Amounts not paid within 30 days will be subject to 1.5% per month interest from date of invoice. We may amend these late payment terms with thirty days’ notice, with notification via email or otherwise. Except as provided in the following sentence, client accounts are also subject to a minimum quarterly fee of $8,750, which is equivalent to our standard percentage fee applied to an account of $3,000,000. Client accounts that start with or move to having a partner-level resource (e.g., our Managing Partner, Thomas Gerson) as their primary advisor are, instead, subject to a higher minimum quarterly fee of $13,750, which is equivalent to our standard percentage fee applied to an account of $5,000,000, where such minimum is not automatically reduced if subsequently a non-partner-level resource is able to serve as primary advisor. The definition of “primary advisor” is at our discretion. When comprehensive portfolio management clients request, and we agree, we will facilitate and provide formal (written) financial modeling and/or planning. For this financial modeling/planning, the fee for the first twenty (20) hours of this service will be deferred until the end of the twelfth month following provision of planning services and, if such payment does not become due by such date, it shall be waived. Fees for services exceeding twenty (20) hours are not deferred and are charged at the hourly rate in effect at that time service is provided for the individual providing the service. If a client ceases to remain a client for such twelve-month period, any deferred fee shall become due and is not waived and will be charged in full, based on our hourly rate in force at the time and the time we spent on the client’s planning, whether completed or not, payable within 30 days or debited against any pro-rata refund due, or a combination. For complex situations, such as international clients, we may not have a maximum percentage fee and instead will have a negotiated fee. We may also increase your minimum fee in the future, pursuant to our regular process for changing fees. Notwithstanding the foregoing, we may, at our discretion, agree to a lower fee for some of our clients, and we and our international or other clients with complex circumstances may agree to a greater fee. Account deposits of more than $100,000 can increase the complexity of our work and will result in an incremental fee, at our rates above, for the immediate fractional quarter rather than waiting to impact fees until the start of the next quarter. Any such incremental fee shall be based on the deposit amount for that initial fractional quarter. Any such incremental fee will be due immediately at the beginning of the next quarter, when fees are generally paid in advance. In this fashion fees are still only collected once a quarter. Various additional fees may apply for financial planning. For the avoidance of doubt, planning is only available to clients of our Comprehensive Portfolio Management Service. When financial plans include planning for assets of any type not under our management (investment portfolio, pension plans, art, investment real estate, or anything else besides your primary home), all planning hours more than the initial twelve (12) hours are immediately billable at our applicable hourly rates. Further, the initial twelve (12) hours may become billable in the event of termination. If investment portfolio assets not under our management are more than 25% of the amount of assets that are under our management, then we will also bill for the initial twelve (12) hours (i.e., in the case where we are managing less than 80% of a client’s investment assets, all planning activity is billable, with none of it “deferred” or complimentary). ADV Part 2A – Firm Brochure Page 9 Blair Hall Advisors, LLC  For all financial planning work, there will be a per hour handling charge for scanning, organizing, and shredding of any hard copy materials sent to us to aid in planning at our applicable “clerical” rate; materials sent to us electronically will have no such charge; hard copy materials will be destroyed rather than returned. Additional fees may also apply for complex planning, or for planning multiple scenarios. For any additional formal written planning (for example, not “on schedule” for a client’s asset level with us), there are several constraints: such planning is (a) subject to resource availability, (b) subject to a minimum project size of fifteen hours (15) hours; and (c) payment for minimum project size will be due before work begins. Up to $9,000 of any planning fees may be deducted directly from your accounts if feasible, and additionally we may carry up to another $9,000 forward for one additional quarter, to be directly deducted from your account. These fees may be negotiable at the discretion of the firm. We reserve the right to decline to perform “complex” planning. If outside attorneys or accountants (or unusual experts) are required to be involved, those costs are to be paid be clients at cost, and in most cases paid directly by clients; attorneys and accountants (or unusual experts) will only be engaged with client approval. In the course of financial planning, we may provide recommendations that can or should be implemented through third parties. As part of our firm’s overall billing process, clients understand the following: An independent custodian sends statements at least quarterly to clients showing the market values for each security included in the Assets and all disbursements in client accounts including the amount of the advisory fees paid to us. Clients provide authorization permitting us to be directly paid in accordance with these terms, including deducting our advisory fees from the account held with the custodian. We may modify any aspect of our fees effective at any time one year or more after a client enters into a Master Services Agreement with us, with thirty days’ notice, with notification via email or otherwise. Comprehensive Portfolio Management, Financial Planning Hourly Rates: Our hourly rate for financial planning is in the chart below in the column labeled “Planning” for all planning staff or contractors; wealth managers; other skilled titles that may arise in our business, except for our Managing Partner, for whom it is up to double. This rate applies to the preponderance of tasks. Our hourly rate for clerical-only staff is in the chart below in the column labeled “Clerical.” The main tasks that this rate would apply to would be the scanning and basic handling of any incoming paper documents. We may track efforts in 15-minute increments, rounding up, or we may use smaller increments, at our discretion. ADV Part 2A – Firm Brochure Page 10 Blair Hall Advisors, LLC  Calendar Year Clerical Rate 2025 2026 2027 2028 2029 2030 Hourly Rates Planning Rate (up to double this amount for Managing Partner) $401 $417 $440 $465 $495 $525 $180 $200 $200 $220 $220 $240 We reserve the right to charge less than the above rates if we wish. Appointment cancelation policy Clients who cancel or reschedule an appointment with less than two full business days of notice for an appointment more than once in any rolling twelve-month period may be charged one-and-a-half hours of time for all resources of the Company who were scheduled for involvement in that appointment, whether it is a remote meeting or an in-person meeting. This cost will be added to the next quarterly fee. The twelve-month period does not reset until there have been twelve consecutive months without this policy being violated. An example for clarity on “two full business days” would be that a Tuesday 2pm appointment would need to be canceled before 2pm on Friday. The Company staff are highly utilized and are not responsible for reminding Clients of their appointments. Hourly rates are listed elsewhere in this Agreement. Such a charge will be listed on a Client's billing statement if a billing statement is required per Client's regulatory jurisdiction. Exclusivity Expectations and Non- Exclusive Minimum Fees BHA’s exclusivity standard exists to ensure clear accountability and fully coordinated advice. When BHA is not serving as the exclusive advisor, it adds complexity and cost to our efforts, as we must strive to account for outside activity that could be at cross-purposes to our efforts. While we make an effort to remain aware of such circumstances, we cannot guarantee our effectiveness in doing so. We expect that BHA will manage at least 90% (ninety percent) of clients’ total investment assets that are reasonably transferable to our management, including taxable brokerage accounts, IRAs, inherited IRAs, trust accounts, and similar accounts. For purposes of this standard, we do not count as “investment assets” accounts like (a) current employer retirement plans that cannot be transferred, (b) former employer retirement plans unless clients request (or we perhaps recommend and you independently agree), (c) 529 accounts, or (d) checking accounts and other short-term-need bank accounts. (Accounts that are within an annuity wrapper will be disclosed to us to evaluate and to discuss with you but are also not automatically included as investment assets that we expect to manage.) This exclusivity standard applies to all investment assets held at the time of this agreement as well as any new investment assets you acquire hereafter, including through inheritance, trust distribution, business or property sale, or other means. Clients agree to notify us within 60 days if such a change in their investment assets occurs. ADV Part 2A – Firm Brochure Page 11 Blair Hall Advisors, LLC  The purpose of the 10% (ten percent) amount that is not subject to this exclusivity standard is that, in our experience, it is important to some clients to continue doing a limited amount of personal stock-picking or angel investing. If, at any time, clients do not maintain this 90% threshold, their fee shifts to a 1.75% annual asset- based fee and a $13,750 quarterly minimum, whichever is higher at the start of any given quarter. This percentage and quarterly minimum are known as our Non-Exclusive Minimum Fees, which clients also are free to select if they wish to operate on a non-exclusive basis with us. All investment assets we do not manage must remain self-directed (i.e., not managed by any third- party investment advisor or discretionary manager). For avoidance of doubt, a client who has another third-party advisor or discretionary manager for this 10% (ten percent) would be subject to our Non-Exclusive Minimum Fees. Other Types of Fees & Expenses Clients will incur transaction fees for trades executed by the custodian via individual transaction charges. These transaction fees are separate from our firm’s advisory fees and will be disclosed by the custodian. Charles Schwab & Co., Inc. (“Schwab”) does not currently charge transaction fees for U.S. listed equities and exchange traded funds. Clients may also pay holdings charges imposed by the chosen custodian for certain investments, charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, and other fund expenses), mark-ups and mark- downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these fees. Termination & Refunds Either party may terminate our Agreement in writing at any time. Upon receipt of notice of termination, our firm will process a pro-rata refund of the unearned portion of the advisory fees charged in advance at the beginning of the quarter. We retain the right to provide up to thirty days’ notice of termination if we believe it would be mutually beneficial. If our work together continues in such an up-to-thirty-day notice period, a pro-rata refund is issued instead at the end of our time working together and adjusted accordingly. If we or a client terminate our working relationship within 12 months of any formal planning, planning will be charged in full, based on our hourly rate in force at the time and the time we spent on the client’s planning, whether completed or not, payable within 30 days or debited against any pro-rata refund due, or a combination. When services are terminated, we will deliver any usable sections of any financial planning, analysis or other work product that is complete. If work product is not in a reliable state (e.g., not validated or lacking input or work), we may determine in our sole discretion not to deliver it to avoid inappropriate reliance on it. If payment is due for such work, we will refrain from delivering until paid in full. Commissionable Securities Sales ADV Part 2A – Firm Brochure Page 12 Blair Hall Advisors, LLC  Our firm and representatives do not sell securities for a commission in advisory accounts. Item 6: Performance-Based Fees & Side-By-Side Management Our firm does not charge performance-based fees. Item 7: Types of Clients & Account Requirements We have or may have the following types of clients: • Individuals and High Net Worth Individuals • Trusts, Estates or Charitable Organizations • Corporations, Limited Liability Companies and/or Other Business Types Our requirements for opening and maintaining accounts or otherwise engaging us: • We require an account balance of $5,000,000 for our Comprehensive Portfolio Management for retired clients new to our firm. We require an account balance of $3,000,000 for individuals and families in the accumulation stage. This minimum account balance is negotiable at the discretion of our firm. A minimum fee will apply as outlined in Item 5 of this brochure. • Clients who do not maintain 90% or more of their investment assets, as outlined in Item 5 of this brochure, are subject to the Firm’s Non-Exclusive Minimum Fees, also outlined in Item of this brochure. . • Usually we work as a client’s only advisory firm, in order to maximize our benefit to clients, and any investment assets we do not manage must remain self-directed, as outlined in Item 5 of this brochure. • We reserve the right to decline to work with any client for any reason. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Methods of Analysis Generally, Blair Hall Advisors uses a variety of analytical methods to assist with its security, investments, and markets analysis. Such methods employed by us may include: 1. Technical analysis for short-term market analysis. This type of analysis focuses on studying trends in price movements, with the aim of ascertaining short-term price changes. Please see “RISK OF LOSS” discussion, below. 2. Quantitative and fundamental analysis for long-term security and investment analysis. This type of analysis focuses on studying the underlying value of securities compared to their current market prices, with the aim of ascertaining disparities between current prices and long-term value. Please see “RISK OF LOSS” discussion, below. The main sources of information include Morningstar, Google Finance, fund prospectuses, various online and written economic reports, financial newspapers, and other public and proprietary research materials. Investment Strategies We Use ADV Part 2A – Firm Brochure Page 13 Blair Hall Advisors, LLC  The investment strategies we may pursue on behalf of clients may include long- and short-term purchases, short-term trading, option writing or purchasing (including covered options, uncovered options or spreading strategies), margin transactions, and other strategies depending on the particular needs and objectives of the client. We may also pursue the use of so-called alternative investments, such as hedge funds and private equity. Please see “RISK OF LOSS” discussion, just below. We generally invest client’s cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper or government backed debt instruments or a default cash option of our custodian’s choosing. Ultimately, we try to achieve an appropriate return on our client’s cash balances through relatively low risk and conservative investments. In most cases, at least a small percentage cash balance will be maintained in a money market account or a default cash option of our custodian’s choosing so that our firm may debit advisory fees for our services related to our Comprehensive Portfolio Management service and because it facilitates smooth trading on clients’ behalf. The SMAs used by our firm offer a way to combine academically informed investment approaches and a level of personalization for our clients. Our firm can tailor select strategies to better fit our client’s financial goals, preferences, and values, be it for environmental, social, and governance (ESG) preferences, tax management strategy, individual stock and sector holdings, and more. Risk of Loss Investing in securities or other investments involves a significant risk of loss which clients should be prepared to bear. Blair Hall Advisors’ investment recommendations are subject to various market, currency, economic, political and business risks, and such investment decisions may not always be profitable. Clients should be aware that there may be a loss or depreciation to the value of the client’s account. There can be no assurance that the client’s investment objectives will be obtained and no inference to the contrary should be made. The risks involved in the securities and investments recommended by Blair Hall Advisors may include, among others: • • Stock (or bond) market risk, which is the chance that stock (or bond) prices overall will decline. Stock (or bond) markets tend to move in cycles, with periods of rising prices and periods of falling prices. Equity securities generally have greater price volatility than fixed income securities. Issuer risk, which is the risk that the value of a security may decline for reasons directly related to the issuer, such as management performance, financial leverage, and reduced demand for the issuer's goods or services. • Exchange Traded Fund (ETF) risk, which is the risk of an investment in an ETF, including the possible loss of principal. ETFs typically trade on a securities exchange and the prices of their shares fluctuate throughout the day based on supply and demand, which may not correlate to their net asset values. Although ETF shares will be listed on an exchange, there can be no guarantee that an active trading market will develop or continue. Owning an ETF generally reflects the risks of owning the underlying securities it is designed to track. ETFs are also subject to secondary market trading risks. In addition, an ETF may not replicate exactly the performance of the index it seeks to track for a number of reasons, including transaction costs incurred by the ETF, the temporary unavailability of certain securities in the secondary market, or discrepancies between the ETF and the index with respect to weighting of securities or number of securities ADV Part 2A – Firm Brochure Page 14 Blair Hall Advisors, LLC  held. • Non-diversification risk, which is the risk of focusing investments in a small number of issuers, industries or foreign currencies, including being more susceptible to risks associated with a single economic, political or regulatory occurrence than a more diversified portfolio might be. • Style risk, which is the risk that the use of a particular investing style (such as growth or value investing) may fall out of favor or may not produce the best results over short or longer time periods. Different investment styles tend to shift in and out of favor depending upon market and economic conditions and investor sentiment. To the extent that a Blair Hall Advisors portfolio favors a particular investment style, it may underperform other portfolios that invest in similar asset classes but employ different investment styles, or if the style it favors underperforms the overall market. • Foreign (non-U.S.) investment risk, which is the risk that investing in foreign securities may result in the portfolio experiencing more rapid and extreme changes in value than a portfolio that invests exclusively in securities of U.S. companies. Investments in emerging markets are generally more volatile than investments in developed foreign markets. • • Short sale risk, which is the risk of entering into short sales, including the potential loss of more money than the actual cost of the investment, and the risk that the third party to the short sale may fail to honor its contract terms, resulting in a loss. Interest rate risk, which is the chance that bond prices overall will decline because of rising interest rates. Similarly, the income from bonds or other debt instruments may decline because of falling interest rates. • Credit risk, which is the chance that a bond issuer will fail to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of that bond to decline. • Smaller company risk, which is the risk that the value of securities issued by a smaller company may go up or down, sometimes rapidly and unpredictably as compared to more widely held securities. Investments in smaller companies are subject to greater levels of credit, market and issuer risk. • Options risk, which is the risk that options may be subject to greater fluctuations in value than an investment in the underlying securities. Options and other derivatives may be subject to counterparty risk and may also be illiquid and more difficult to value. Purchasing and writing put and call options are highly specialized activities and entail greater than ordinary investment risks. • Margin trading risk, which is the risk of purchasing securities on margin. Margin trading involves interest charges and risks, including but not limited to the potential to lose more than deposited or the need to deposit additional collateral in a falling market and the incurrence of margin interest debt. Margin borrowing adds risk to an investment and is not suitable for all investors. • Management risk, which is the risk that the investment techniques and risk analyses applied by Blair Hall Advisors will produce the desired results and that legislative, regulatory, or tax developments may affect the investment techniques available to us. There is no guarantee that a client’s investment objectives will be achieved. • Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Please note, all investing involves the risk of loss that clients should be prepared to bear. While markets and alternative investments may increase and your account(s) could enjoy ADV Part 2A – Firm Brochure Page 15 Blair Hall Advisors, LLC  a gain, it is also possible that the inverse may occur, and your account(s) could suffer a loss. It is important that you understand the risks associated with investing and are appropriately diversified in your investments. Please feel free to ask us any questions you may have. Item 9: Disciplinary Information There are no legal or disciplinary events that are material to the evaluation of our advisory business or the integrity of our management. Item 10: Other Financial Industry Activities & Affiliations A representative of our firm, Joao Correia, is registered with more than one Registered Investment Advisor (“RIA”) firm. As such, a conflict of interest may arise because of his being an IAR for multiple RIAs. To mitigate this conflict, Mr. Correia, as a fiduciary, will act in the client’s best interest. Furthermore, any services that may be offered through the outside RIAs will remain separate from our firm’s advisory services and are governed under a separate agreement. Our firm is not registered, nor does it have an application pending to register, as a broker-dealer, registered representative of a broker dealer, investment company or pooled investment vehicle, other investment adviser or financial planner, futures commission merchant, commodity pool operator, commodity trading advisor, banking or thrift institution, accountant or accounting firm, lawyer or law firm, insurance company or agency, pension consultant, real estate broker or dealer or a sponsor or syndicator of limited partnership, or an associated person of the foregoing entities. Please see Item 4 for more information regarding our firm’s selection of third-party managers. When in the client’s best interest, our firm will recommend select sub-advisory services. Prior to recommending third-party managers, our firm will ensure that the third-party manager is properly licensed or registered with the respective authorities. Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading We recognize that the personal investment transactions of members and employees of our firm demand the application of a high code of ethics and require that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, we believe that if investment goals are similar for clients and for members and employees of our firm, it is logical and even desirable that there be common ownership of some securities. Therefore, to prevent conflicts of interest, we have in place a set of procedures (including a pre- clearing procedure) with respect to transactions effected by our members, officers and employees for their personal accounts. To monitor compliance with our personal trading policy, we have a quarterly securities transaction reporting system for all our associates. Furthermore, our firm has established a Code of Ethics which applies to all our associated persons. An investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. We have a fiduciary duty to all clients. ADV Part 2A – Firm Brochure Page 16 Blair Hall Advisors, LLC  Our fiduciary duty is considered the core underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities Transactions Policies and Procedures. We require all our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. Neither our firm nor a related person recommends to clients, or buys or sells for client accounts, securities or other investments in which our firm or a related person has a material financial interest. Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. To minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Further, in accordance with standard “front running” guidelines, no related persons may enter an order to purchase or sell any security prior to a transaction of the same security being implemented for client’s accounts on the same day. Our firm’s CCO will review and may approve exceptions on a case-by-case basis if it is determined that the trading activity does not violate our firm’s fiduciary duty. Instances in which exemptions may be granted may include (but are not limited to): • A related person executes a transaction before a client solicits a trade in the same security. • A related person participates in a block trade alongside client accounts; or • A related person without access to another investment advisor at our firm’s trading activity executes a transaction in the same security as the investment advisor’s advisory client. Item 12: Brokerage Practices Selecting a Brokerage Firm We seek to recommend a custodian/broker-dealer that will hold your assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. We consider a wide range of factors in selecting or recommending broker-dealers, including, among others, these: • Ability to maintain the confidentiality of trading intentions • Timeliness of execution • Timeliness and accuracy of trade confirmations • Liquidity of the securities traded • Willingness to commit capital • Ability to place trades in difficult market environments • Research services provided • Ability to provide investment ideas • Execution facilitation services provided • Record keeping services provided • Custody services provided • Frequency and correction of trading errors • Ability to access a variety of market venues • Expertise as it relates to specific securities ADV Part 2A – Firm Brochure Page 17 Blair Hall Advisors, LLC  • Financial condition • Business reputation With this in consideration, our firm has arrangements with the Schwab Institutional division of Charles Schwab & Co., Inc. (“Schwab”) and Interactive Brokers, Inc. Both companies offer independent investment advisers non-soft dollar services which include custody of securities, trade execution, clearance and settlement of transactions. Schwab and Interactive Brokers may make certain research and brokerage services available at no additional cost to our firm. These services may be directly from independent research companies, as selected by our firm (within specific parameters). Research products and services provided by Schwab or Interactive Brokers may include: research reports or other information about particular companies or industries; economic surveys, data and analyses; financial publications; portfolio evaluation services; financial database software and services; computerized news and pricing services; quotation equipment for use in running software used in investment decision-making; and other products or services that provide lawful and appropriate assistance by Schwab and Interactive Brokers to our firm in the performance of our investment decision-making responsibilities. We do not use client brokerage commissions to obtain research or other products or services. The aforementioned research and brokerage services are used by our firm to manage accounts for which we have investment discretion. Without this arrangement, our firm might be compelled to purchase the same or similar services at our own expense. We may have an incentive to continue to use or expand the use of Schwab’s and Interactive Brokers’ services. Our firm examined this potential conflict of interest when we chose to enter into the relationship with Schwab and we have determined that the relationship is in the best interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best execution. Schwab and Interactive Brokers charge brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). Schwab enables us to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Schwab commission rates are generally discounted from customary retail commission rates. However, the commission and transaction fees charged by Schwab may be higher or lower than those charged by other custodians and broker-dealers. Our clients may pay a commission to Schwab or Interactive Brokers that is higher than another qualified broker dealer might charge to effect the same transaction where we determine in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive rates, to the benefit of all clients, we may not necessarily obtain the lowest possible commission rates for specific client account transactions. ADV Part 2A – Firm Brochure Page 18 Blair Hall Advisors, LLC  We do not receive soft dollars generated by the securities transactions of our clients. The term "soft dollars" refers to funds which are generated by client trades “commission rebates or credits” being used by our firm to purchase products or services (such as research and enhanced brokerage services) from or through Schwab or Interactive Brokers to execute securities transactions. The non- soft dollar investment research products and services that may be obtained by our firm will generally be used to service all of our clients. A brokerage commission paid by a specific client may be used to pay for research that is not used in managing that specific client’s account. Our firm, however, does receive some “eligible” products and services under the safe harbor provision under the Securities and Exchange Act, Section 28(e). These products and services include: educational events; professional compliance; legal and business consulting; publications and conferences on practice management; information technology; business succession; employee benefits providers; human capital consultants; insurance; and marketing. In addition, Schwab or Interactive Brokers may make available, arrange and/or pay vendors for these types of services rendered to our firm by independent third parties. Schwab or Interactive Brokers may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to our firm. While, as a fiduciary, our firm endeavors to act in its clients’ best interests, our firm’s recommendation of Schwab or Interactive Brokers may be based in part on the benefit we receive as described above and not solely on the nature, cost, or quality of custody and brokerage services provided by broker-dealers, which may create a potential conflict of interest. As a result of receiving such “eligible” products and services for no cost, we may have an incentive to continue to place client trades through Schwab or Interactive Brokers for offering those products and services. This interest conflicts with the clients' interest of obtaining the lowest commission rate available. Therefore, we must determine in good faith, that such commissions are reasonable in relation to the value of the services provided by such executing broker-dealer. Our firm examined this potential conflict of interest when we chose to enter into the relationship with Schwab or Interactive Brokers and we have determined that the relationship is in the best interest of our firm’s clients and satisfies our client obligations, including our duty to seek best execution. Further, we continually keep this conflict in mind as we are continually considering our business arrangements. We perform investment management services for various clients. There are occasions on which portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same security for numerous accounts served by our firm, which involve accounts with similar investment objectives. Although such concurrent authorizations potentially could be either advantageous or disadvantageous to any one or more particular accounts, they are affected only when we believe that to do so will be in the best interest of the effected accounts. When such concurrent authorizations occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts involved. In any given situation, we attempt to allocate trade executions in the most equitable manner possible, taking into consideration client objectives, current asset allocation and availability of funds using price averaging, proration and consistently non- arbitrary methods of allocation. Our firm does not receive brokerage services for client referrals. We do not permit clients to direct brokerage. ADV Part 2A – Firm Brochure Page 19 Blair Hall Advisors, LLC  Item 13: Review of Accounts or Financial Plans Thomas Gerson, Chief Compliance Officer, reviews accounts on at least a quarterly basis for our clients subscribing to our Comprehensive Portfolio Management service unless a client’s balance is below $250,000, in which case account reviews may be performed annually rather than quarterly, unless more frequent reviews are warranted due to changes in financial circumstances, specific client requests, or adviser discretion. In all cases, the nature of these reviews is to learn whether clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Our firm may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. We do not provide written reports to clients, unless asked to do so or we feel it is necessary to aid decision-making. Oral reports to clients take place on at least an annual basis when we contact our clients. Item 14: Client Referrals & Other Compensation Charles Schwab & Co., Inc. We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors that have their clients maintain accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability to us of Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. Referral Fees Our firm does not pay referral fees (non-commission based) to independent solicitors (non- registered representatives) for the referral of their clients to our firm in accordance with relevant state statutes and rules. Item 15: Custody Deduction of Advisory Fees: Our firm does not maintain custody of client funds. When the firm directly deducts clients’ fees, regulators recognize this practice as conveying upon the firm constructive custody. As such, our firm has adopted the following safeguarding procedures: a) Clients must provide our firm with written authorization permitting direct payment of advisory fees from their account(s) maintained by a custodian who is independent of our firm; b) The account custodian sends a statement to all clients, at least quarterly, showing all account disbursements, including advisory fees. ADV Part 2A – Firm Brochure Page 20 Blair Hall Advisors, LLC  An independent custodian sends statements at least quarterly to clients showing the market values for each security included in the Assets and all disbursements in client accounts including the amount of the advisory fees paid to our firm, and we encourage clients to review these statements for accuracy. Additionally, the client understands that they provide authorization permitting our firm to be directly paid in accordance with these terms, including deducting our advisory fees from the account held with their independent custodian. Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. Item 16: Investment Discretion Clients have the option of providing our firm with investment discretion on their behalf, pursuant to an executed investment advisory client agreement. By granting investment discretion, our firm is authorized to execute securities transactions, determine which securities are bought and sold, and the total amount to be bought and sold, and the costs at which transactions will be effected. Should clients grant our firm non-discretionary authority, our firm would be required to obtain the client’s permission prior to effecting securities transactions. Limitations may be imposed by the client in the form of specific constraints on any of these areas of discretion with our firm’s written acknowledgement. Item 17: Voting Client Securities Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, our firm will forward them to the appropriate client and ask the party who sent them to mail them directly to the client in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. Item 18: Financial Information Inclusion of a Balance Sheet Our firm does not require nor is prepayment solicited for more than $1,200 in fees per client, 6 months or more in advance. Therefore, our firm has not included a balance sheet for our most recent fiscal year. Disclosure of Financial Condition Our firm has nothing to disclose in this regard. Bankruptcy Petition Our firm has never been the subject of a bankruptcy proceeding. ADV Part 2A – Firm Brochure Page 21 Blair Hall Advisors, LLC