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HERITAGE HAUS WEALTH PARTNERS LLC ADV 2
Heritage Haus Wealth Partners LLC (CRD 342736), brochure dated October 5, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
Item 1 – Cover Page
Part 2A of Form ADV
Heritage Haus Wealth Partners LLC
Physical Address: 1176 N. Business IH 35, New Braunfels, TX 78130
Mailing Address: 146 S. State Highway 46, New Braunfels, TX 78130
Phone: (830) 316-3590
Email: msrulowitz@heritagehauswp.com
Website: www.heritagehauswealth.com
October 5, 2026
This Brochure provides information about the qualifications and business practices of
Heritage Haus Wealth Partners LLC. If you have any questions about the contents of this
Brochure, please contact us using the information listed above. The information in this
Brochure has not been approved or verified by the United States Securities and
Exchange Commission (“SEC”) or by any state securities authority.
Heritage Haus Wealth Partners LLC (CRD# 342736) is a registered investment advisor
with the SEC. Registration of an investment advisor does not imply any certain level of
skill or training.
Additional information about Heritage Haus Wealth Partners LLC is also available on the
SEC’s website at www.adviserinfo.sec.gov.
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Item 2 – Material Changes
This Brochure has been updated to reflect the following material changes since the Firm’s
last update:
The Firm’s physical address has been updated to 1176 N. Business IH 35, New
Braunfels, TX 78130.
The Firm’s mailing address has been updated to 146 S. State Highway 46, New
Braunfels, TX 78130.
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Item 3 – Table of 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 and Compensation ....................................................................................7
Item 6 - Performance-Based Fees and Side-By-Side Management ..........................9
Item 7 – Types of Clients & Account Minimums ......................................................... 10
Item 8 – Methods of Analysis, Investment Strategies, Investment Tools, and Risk of Loss
............................................................................................................................. 10
Item 9 – Disciplinary Information .................................................................................. 16
Item 10 – Other Financial Industry Activities and Affiliations ................................... 16
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ............................................................................................................... 16
Item 12 – Brokerage Practices ....................................................................................... 18
Item 13 – Review of Accounts ........................................................................................ 19
Item 14 – Client Referrals and Other Compensation .................................................. 19
Item 15 – Custody ............................................................................................................ 20
Item 16 – Investment Discretion .................................................................................... 21
Item 17 – Voting Client Securities ................................................................................. 21
Item 18 – Financial Information ..................................................................................... 21
Supervised Person Brochure – Michael Samuel Srulowitz ....................................... 23
Supervised Person Brochure – Michael Francisco Gaona ........................................ 25
Supervised Person Brochure – Tanner J. Friesenhahn ............................................. 27
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Item 4 – Advisory Business
Description of the Advisory Firm
A.
Heritage Haus Wealth Partners LLC (“Heritage Haus Wealth”) was formed on May 5, 2026,
and is based in New Braunfels, TX. Heritage Haus Wealth is owned by Michael Srulowitz and
Michael Gaona.
Types of Advisory Services
B.
WEALTH MANAGEMENT
Heritage Haus Wealth offers three levels of wealth management services to advisory clients:
Foundation Wealth Management
Heritage Haus Wealth offers foundation wealth management services which include
asset management and financial planning. Foundation Wealth Management is ideal for
clients with up to $250,000 in assets under management.
Comprehensive Wealth Management
Heritage Haus Wealth offers comprehensive wealth management services which
include asset management, financial planning, tax plan review and estate plan review.
Comprehensive Wealth Management is ideal for clients with up to $500,000 in assets
under management.
Complex Wealth Management
Heritage Haus Wealth offers complex wealth management services which include
asset management, financial planning, tax planning, estate plan review and
coordinating with the client’s tax accountant or tax attorney and coordinating with an
estate planning attorney. Comprehensive Wealth Management is ideal for clients with
more than $500,000 in assets under management.
Heritage Haus Wealth will offer clients ongoing wealth management services through
determining individual investment goals, time horizons, objectives, and risk tolerance.
Investment strategies, investment selection, asset allocation, portfolio monitoring and the
overall investment program will be based on the above factors.
Discretionary
When the client elects to use Heritage Haus Wealth on a discretionary basis, the client
will sign a limited trading authorization or equivalent allowing Heritage Haus Wealth to
determine the securities to be bought or sold and the amount of the securities to be
bought or sold. Heritage Haus Wealth will have the authority to execute transactions
in the account without seeking client consent on each transaction.
HELD-AWAY ASSETS
Heritage Haus Wealth utilizes a third-party platform to facilitate the management of held-
away assets, in which we will have discretionary authority. These are primarily 401(k)
accounts, 529 Plans, HSAs, and other assets which are held at third-party custodians.
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Heritage Haus Wealth regularly reviews, monitors and trades in these accounts in the same
way we do other accounts. Heritage Haus Wealth will seek to align the client’s held-away
account(s) with their overall investment time horizon, risk tolerance, objectives and goals.
ERISA PLAN SERVICES
Heritage Haus Wealth offers service to qualified and non-qualified retirement plans including
401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred
compensation plans (“Plan”).
Limited Scope ERISA 3(21) Fiduciary. Heritage Haus Wealth acts as a limited scope
ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their
investment decisions. As an investment advisor Heritage Haus Wealth has a fiduciary
duty to act in the best interest of the client. The plan sponsor is still ultimately
responsible for the decisions made in their plan, though using Heritage Haus Wealth
can help the plan sponsor delegate liability by following a diligent process.
1. Fiduciary Services are:
• Provide investment advice to the Plan about asset classes and investment
alternatives available for the Plan in accordance with the Plan’s investment policies
and objectives. The Plan Sponsor will make the final decision regarding the initial
selection, retention, removal and addition of investment options. Heritage Haus
Wealth acknowledges that it is a fiduciary as defined in ERISA section 3(21) (A) (ii).
• Assist the Plan in the development of an investment policy statement (“IPS”). The
IPS establishes the investment policies and objectives for the Plan. Plan shall have
the ultimate responsibility and authority to establish such policies and objectives
and to adopt and amend the IPS.
• Provide investment advice to the Plan Sponsor with respect to the selection of a
qualified default investment alternative (“QDIA”) for participants who are
automatically enrolled in the Plan or who have otherwise failed to make investment
elections. The Plan retains the sole responsibility to provide all notices to the Plan
participants required under ERISA Section 404(c)(5) and 404(a)5.
• Assist in monitoring investment options by preparing periodic investment reports
that document investment performance, consistency of fund management and
conformance to the guidelines set forth in the IPS and make recommendations to
maintain, remove or replace investment options.
• Meet with the Plan Sponsor on a periodic basis to discuss the reports and the
investment recommendations.
2. Non-fiduciary Services are:
• Assist in the education of Plan participants with general investment information
and the investment alternatives available to them under the Plan. Plan understands
Heritage Haus Wealth’s assistance in education of the Plan participants shall be
consistent with and within the scope of the Department of Labor’s definition of
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investment education (Department of Labor Interpretive Bulletin 96-1). As such,
Heritage Haus Wealth does not provide fiduciary advice as defined by ERISA
3(21)(A)(ii) to the Plan participants. Heritage Haus Wealth will not provide
investment advice concerning the prudence of any investment option or
combination of investment options for a particular participant or beneficiary under
the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by
the employees.
Heritage Haus Wealth may provide these services or, alternatively, may arrange for
the Plan’s other providers to offer these services, as agreed upon between Heritage
Haus Wealth and the Plan.
3. Heritage Haus Wealth has no responsibility to provide services related to the
following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
• Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of fees paid to Heritage Haus
Wealth on the ERISA Agreement. Specific services will be outlined in detail to each
plan in the 408(b)2 disclosure.
ESTATE PLANNING SERVICES
Through our partnership with an independent third-party technology company, Wealth, Inc.
(“Wealth”), we can facilitate the preparation of various estate planning documents for clients.
Such services are generally separate from any investment management and/or financial
planning services that we may render to a client, and the exact scope of such estate planning
services will depend on the nature of a client’s specific estate planning needs. As a condition
of utilizing Wealth, you must agree to the terms and conditions available at wealth.com.
We may pay for your access to Wealth. For the avoidance of doubt, neither Heritage Haus
Wealth nor Wealth renders legal advice or services. Wealth offers the ability to consult with
licensed attorneys in various jurisdictions at an additional charge, and subject to additional
terms and conditions.
If a conflict of interest exists between the interests of Heritage Haus Wealth and the interests
of the client, the client is under no obligation to act upon Heritage Haus Wealth Partner’s
recommendation. If the client elects to act on any of the recommendations, the client is under
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no obligation to affect the transaction through Heritage Haus Wealth.
SEMINARS AND WORKSHOPS
Heritage Haus Wealth holds seminars and workshops to educate the public on different types
of investments and the different services they offer. The seminars are educational in nature,
and no specific investment or tax advice is given.
Client-Tailored Services and Client-Imposed Restrictions
C.
The client’s financial needs, investment goals, tolerance for risk, and investment objectives
are documented in Heritage Haus Wealth’s client files. Investment strategies are created that
reflect the stated goals and objectives. Clients may impose restrictions on investing in certain
securities or types of securities. These restrictions may, however, prohibit engagement with
Heritage Haus Wealth.
Wrap Fee Programs
D.
Heritage Haus Wealth does not participate in a Wrap Program.
Amounts Under Management
E.
As of September 10, 2026, Heritage Haus Wealth has $241,051,249 discretionary assets
under management.
As of September 10, 2026, Heritage Haus Wealth has $1,000,000 of ERISA Section 3(21)
assets under advisement.
Item 5 – Fees and Compensation
A.
Fee Schedule
WEALTH MANAGEMENT
Heritage Haus Wealth charges an annual investment advisory fee based on the total assets
under management as follows:
Assets Under Management
Maximum Annual Fee
$0 - $250,000
1.20%
$250,001 - $500,000
1.10%
$500,001 - $999,999
1.00%
$1,000,000 - $2,999,999
0.90%
$3,000,000 and above
Negotiable
The minimum annual fee based on assets under management is $2,000. This is greater than
the stated maximum fee of 1.20% when the account, or aggregate accounts, value is below
~$167,000.
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This is a tiered or breakpoint fee schedule, meaning the entire account is charged the same
management fee.
Fees are billed monthly in arrears based on the amount of assets managed as of the close of
business on the last business day of the previous billing period
Please note that Heritage Haus Wealth may group certain related client accounts, often
known as “householding”, for the purposes of achieving the minimum annualized fee.
HELD-AWAY ASSETS
For client accounts held at a custodian that is not directly accessible by Heritage Haus
Wealth, such as held-away assets, Heritage Haus Wealth can manage those assets via a
third-party platform which allows Heritage Haus Wealth to view and manage these assets in
a discretionary manner. Held-away assets will be included in the client’s total assets subject
to the fee schedule above. However, as it might not be possible to directly debit the fees from
these accounts, those fees will be deducted from the client’s non-qualified account(s), or the
client will be billed directly.
ERISA PLAN SERVICES
The annual fees are based on the market value of the included assets and shall not exceed
1.20%. Fees may be charged quarterly or monthly in arrears or in advance based on the
assets as calculated by the custodian or record keeper of the included assets (without
adjustments for anticipated withdrawals by Plan participants or other anticipated or
scheduled transfers or distribution of assets) on the last business day of the previous billing
period.
The fee schedule, which includes compensation of Heritage Haus Wealth for the services
provided, is described in detail in the ERISA Plan Agreement. The Plan is obligated to pay the
fees; however, the Plan Sponsor may elect to pay the fees. clients may elect to be billed
directly or have fees deducted from Plan assets. Heritage Haus Wealth does not reasonably
expect to receive any additional compensation, directly or indirectly, for its services. If
additional compensation is received, Heritage Haus Wealth will disclose this compensation,
the services rendered, and the payer of compensation.
ESTATE PLANNING SERVICES
Services are generally separate from any investment management and/or financial planning
services that we may render to a client. We may pay for your access to Wealth. Wealth offers
the ability to consult with licensed attorneys in various jurisdictions at an additional charge,
and subject to additional terms and conditions.
SEMINARS AND WORKSHOPS
Heritage Haus Wealth holds seminars and workshops to educate the public on different types
of investments and the different services they offer. The seminars are educational in nature,
and no specific investment or tax advice is given. Heritage Haus Wealth does not charge a
fee for attendance to these seminars.
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Payment of Fees
B.
Wealth Management Fees are generally deducted directly from the client’s account.
ERISA fees are generally deducted directly from the client’s plan assets.
Heritage Haus Wealth in its sole discretion, may charge a lesser investment advisory fee
based upon certain criteria (e.g., historical relationship, type of assets, anticipated future
earning capacity, anticipated future additional assets, dollar amounts of assets to be
managed, related accounts, account composition, negotiations with clients, etc.).
For all services, clients may terminate their engagement with Heritage Haus Wealth within
five (5) business days of signing an Agreement with no obligation and without penalty. After
the initial five (5) business days, the Agreement may be terminated by Heritage Haus Wealth
with thirty (30) days written notice to client and by the client at any time with written notice
to Heritage Haus Wealth. For accounts opened or closed mid-billing period, fees will be
prorated based on the number of days services are provided during the given period. In the
case of hourly engagements, fees will be prorated based on the work completed at the stated
hourly rate. All unpaid earned fees will be due to Heritage Haus Wealth, and all unearned fees
will be refunded to the client. Any increase in fees will be acknowledged in writing by both
parties before any increase in said fees occurs.
Additional Fees
C.
Custodians may charge brokerage commissions, transaction fees, and other related costs
on the purchases or sales of mutual funds, equities, bonds, options, margin interest, and
exchange-traded funds. Mutual funds, money market funds, and exchange-traded funds may
also charge internal management fees, which are disclosed in the fund’s prospectus. Heritage
Haus Wealth does not directly receive any compensation from these fees. All these fees are
in addition to the management fee you pay to Heritage Haus Wealth. For more details on the
brokerage practices, see Item 12 of this brochure.
Prepayment of Fees
D.
Heritage Haus Wealth does not expect clients to prepay fees.
External Compensation for the Sale of Securities
E.
Heritage Haus Wealth does not receive any external compensation from the sale of
securities.
Item 6 - Performance-Based Fees and Side-By-Side Management
Fees are not based on a share of the capital gains or capital appreciation of managed
securities. Heritage Haus Wealth does not use a performance-based fee structure nor “side-
by-side” management because of the conflict of interest. Performance-based compensation
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may create an incentive for Heritage Haus Wealth to recommend an investment that may
carry a higher degree of risk to the client.
Item 7 – Types of Clients & Account Minimums
Heritage Haus Wealth’s clients are generally individuals and high net-worth individuals. Client
relationships vary in scope and length of service.
There is no minimum account size, and clients are not required to have a certain amount of
investment experience or sophistication.
Item 8 – Methods of Analysis, Investment Strategies, Investment Tools, and Risk of Loss
Methods of Analysis and Investment Strategies
A.
Investing in securities involves risk of loss that clients should be prepared to bear. Past
performance is not a guarantee of future returns. Security analysis methods may include:
Fundamental analysis concentrates on factors that determine a company’s value and
expected future earnings. This strategy would normally encourage equity purchases in
stocks that are undervalued or priced below their perceived value. The risk assumed is that
the market will fail to reach expectations of perceived value.
In developing a financial plan for a client, Heritage Haus Wealth’s analysis may include cash
flow analysis, investment planning, risk management, tax planning and estate planning. Based
on the information gathered, a detailed strategy is tailored to the client’s specific situation.
The main sources of information include financial newspapers and magazines, annual
reports, prospectuses, and filings with the SEC.
Investment Strategy
B.
The investment strategy for a specific client is based upon the objectives stated by the client
during consultations. The client may change these objectives at any time by providing written
notice to Heritage Haus Wealth. Each client executes a client profile form or similar form that
documents their objectives and their desired investment strategy.
Risks of Investments and Strategies Utilized
C.
Investing in securities involves risk of loss that clients should be prepared to bear.
Heritage Haus Wealth’s investment approach constantly keeps the risk of loss in mind.
Investors may face the following investment risks:
General Investment and Trading Risks. Clients may invest in securities and other financial
instruments using strategies and investment techniques with significant risk characteristics.
The investment program utilizes such investment techniques as option transactions, margin
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transactions, short sales, leverage, and derivatives trading, the use of which can, in certain
circumstances, maximize the adverse impact to which a client may be subject.
Interest-rate Risk. Fluctuations in interest rates may cause investment prices to fluctuate.
For example, when interest rates rise, yields on existing bonds become less attractive,
causing their market values to decline.
Inflation Risk. When any type of inflation is present, a dollar today will buy more than a dollar
next year, because purchasing power is eroding at the rate of inflation.
Currency Risk. Overseas investments are subject to fluctuations in the value of the dollar
against the currency of the investment’s originating country. This is also referred to as
exchange rate risk.
Reinvestment Risk. This is the risk that future proceeds from investments may have to be
reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed
income securities.
Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. Generally,
assets are more liquid if many traders are interested in a standardized product. For example,
Treasury Bills are highly liquid, while real estate properties are not.
Management Risk. The advisor’s investment approach may fail to produce the intended
results. If the advisor’s assumptions regarding the performance of a specific asset class or
fund are not realized in the expected time frame, the overall performance of the client’s
portfolio may suffer.
Cybersecurity Risk. Heritage Haus Wealth and its service providers may be subject to
operational and information security risks resulting from cyberattacks. Cyberattacks include,
among other behaviors, stealing or corrupting data maintained online or digitally, denial of
service attacks on websites, the unauthorized release of confidential information or various
other forms of cybersecurity breaches. Cybersecurity attacks affecting Heritage Haus
Wealth and its service providers may adversely impact clients. For instance, cyberattacks
may interfere with the processing of transactions, cause the release of private information
about clients, impede trading, subject Heritage Haus Wealth to regulatory fines or financial
losses, and cause reputational damage. Similar types of cybersecurity risks are also present
for issuers of securities in which clients may invest, qualified custodians, governmental and
other regulatory authorities, exchange and other financial market operators, or other financial
institutions. Cybersecurity incidents that could ultimately cause them to incur losses,
including for example: financial losses, cost and reputational damage, and loss from damage
or interruption of systems. Although Heritage Haus Wealth has established its systems to
reduce the risk of these incidents from coming to fruition, there is no guarantee that these
efforts will always be successful, especially considering that Heritage Haus Wealth does not
directly control the cybersecurity measures and policies employed by third party service
providers.
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Options Trading. The risks involved with trading options are that they are very time-sensitive
investments. An options contract is generally a few months. The buyer of an option could lose
his or her entire investment even with a correct prediction about the direction and magnitude
of a particular price change if the price change does not occur in the relevant time period
(i.e., before the option expires). Additionally, options are less tangible than some other
investments. An option is a “book-entry” only investment without a paper certificate of
ownership.
Trading on Margin. In a cash account, the risk is limited to the amount of money that has
been invested. In a margin account, risk includes the amount of money invested plus the
amount that has been loaned. As market conditions fluctuate, the value of marginable
securities will also fluctuate, causing a change in the overall account balance and debt ratio.
As a result, if the value of the securities held in a margin account depreciates, the client will
be required to deposit additional cash or make full payment of the margin loan to bring the
account back up to maintenance levels. Clients who cannot comply with such a margin call
may be sold out or bought in by the brokerage firm.
Exchange-Traded Funds. ETFs are a type of index fund bought and sold on a securities
exchange. The risks of owning an ETF generally reflect the risks of owning the underlying
securities they are designed to track, although lack of liquidity in an ETF could result in it
being more volatile and ETFs have management fees that increase their costs. ETFs are also
subject to other risks, including: (i) the risk that their prices may not correlate perfectly with
changes in the underlying reference units; and (ii) the risk of possible trading halts due to
market conditions or other reasons that, in the view of the exchange upon which an ETF
trades, would make trading in the ETF inadvisable.
Mutual Fund Risks. An investment in mutual funds could lose money over short or even long
periods. A mutual fund’s share price and total return are expected to fluctuate within a wide
range, like the fluctuations of the overall stock market.
Dimensional Fund Advisors. Certain mutual funds, such as those issued by Dimensional
Fund Advisors (“DFA”), are generally only available through approved registered investment
advisers. Heritage Haus Wealth is one such approved investment adviser and may use or
recommend DFA mutual funds in providing its advisory services. Upon the termination of
Heritage Haus Wealth’s advisory services, client’s new adviser may maintain or sell out of
DFA mutual fund positions but may be restricted in the ability to purchase additional DFA
mutual fund shares.
Common Stocks and Equity-Related Securities. Certain ETFs or mutual funds hold
common stock. Prices of common stock react to the economic condition of the company that
issued the security, industry and market conditions, and other factors which may fluctuate
widely. Investments related to the value of stocks may rise and fall based on an issuer’s actual
and anticipated earnings, changes in management, the potential for takeovers and
acquisitions, and other economic factors. Similarly, the value of other equity-related
securities, including preferred stock, warrants, and options may also vary widely.
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Small- and Mid-Cap Risks. Certain ETFs and mutual funds hold securities of small- and mid-
cap issuers. Securities of small-cap issuers may present greater risks than those of large-
cap issuers. For example, some small- and mid-cap issuers often have limited product lines,
markets, or financial resources. They may be subject to high volatility in revenues, expenses,
and earnings. Their securities may be thinly traded, may be followed by fewer investment
research analysts, and may be subject to wider price swings and thus may create a greater
chance of loss than when investing in securities of larger-cap issuers. The market prices of
securities of small- and mid-cap issuers generally are more sensitive to changes in earnings
expectations, to corporate developments, and to market rumors than the market prices of
large-cap issuers.
Futures, Commodities, and Derivative Investments. Certain ETFs and mutual funds hold
commodities, commodities contracts, and/or derivative instruments, including futures,
options and swap agreements. The prices of commodities contracts and derivative
instruments, including futures and options, are highly volatile. Payments made pursuant to
swap agreements may also be highly volatile. Price movements of commodities, futures and
options contracts, and payments pursuant to swap agreements are influenced by, among
other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary
and exchange control programs and policies of governments, and national and international
political and economic events and policies. The value of futures, options, and swap
agreements also depends upon the price of the commodities underlying them. In addition,
client assets are subject to the risk of the failure of any of the exchanges on which its
positions trade or of its clearinghouses or counterparties.
Highly Volatile Markets. The prices of financial instruments can be highly volatile. Price
movements of forward and other derivative contracts are influenced by, among other things,
interest rates, changing supply and demand relationships, trade, fiscal, monetary and
exchange control programs and policies of governments, and national and international
political and economic events and policies. Clients are also subject to the risk of failure of any
of the exchanges on which their positions trade or of its clearinghouses.
Non-U.S. Securities. Certain ETFs and mutual funds hold securities of non-U.S. issuers.
Investments in securities of non-U.S. issuers pose a range of potential risks which could
include expropriation, confiscatory taxation, imposition of withholding or other taxes on
dividends, interest, capital gains or other income, political or social instability, illiquidity, price
volatility, and market manipulation. In addition, less information may be available regarding
securities of non-U.S. issuers, and non-U.S. issuers may not be subject to accounting, auditing
and financial reporting standards, and requirements comparable to or as uniform as those of
U.S. issuers.
Emerging Markets. Certain ETFs and mutual funds hold securities of emerging markets
issuers. In addition to the risks associated with investments outside of the United States,
investments in emerging markets (i.e., the developing countries) may involve additional risks.
Emerging markets generally are not as efficient as those in developed countries. In some
cases, a market for the security may not exist locally, and transactions will need to be made
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on a neighboring exchange. Volume and liquidity levels in emerging markets are lower than
in developed countries. When seeking to sell emerging market securities, little or no market
may exist for the securities. In addition, issuers based in emerging markets are not generally
subject to uniform accounting and financial reporting standards, practices, and requirements
comparable to those applicable to issuers based in developed countries, thereby potentially
increasing the risk of fraud or other deceptive practices.
Capitalization Risks. Investing in Companies within the same market capitalization category
carries the risk that the category may be out of favor due to current market conditions or
investor sentiment.
Market Risks. Turbulence in the financial markets and reduced liquidity may negatively affect
the Companies, which could have an adverse effect on each of them. If the securities of the
Companies experience poor liquidity, investors may be unable to transact at advantageous
times or prices, which may decrease the Company’s returns. In addition, there is a risk that
policy changes by central governments and governmental agencies, including the Federal
Reserve or the European Central Bank, which could include increasing interest rates, could
cause increased volatility in financial markets, which could have a negative impact on the
Companies. Furthermore, local, regional, or global events such as war, acts of terrorism, the
spread of infectious illness or other public health issues, recessions, or other events could
have a significant impact on the Companies. For example, the rapid and global spread of
COVID-19, resulted in extreme volatility in the financial markets and severe losses; reduced
liquidity of many Companies’ securities; restrictions on international and, in some cases, local
travel; significant disruptions to business operations (including business closures); strained
healthcare systems; disruptions to supply chains, consumer demand and employee
availability; and widespread uncertainty regarding the duration and long-term effects of this
pandemic. Some sectors of the economy and individual issuers experienced particularly large
losses. In addition, the COVID-19 pandemic resulted in increased volatility and/or decreased
liquidity in the securities markets. The Companies’ values could decline over short periods
due to short-term market movements and over longer periods during market downturns.
Inverse and Leveraged Products. Heritage Haus Wealth may recommend and engage in
trading with leveraged and inverse products. These products are aggressive in nature and
carry unusual and significant risk. They are not appropriate for inexperienced investors.
These products are intended to be used/traded daily. Most leveraged and inverse ETFs reset
on a daily basis and have published prospectuses that state (I) they're designed to achieve
their stated objective within one day, (2) clients can lose all of their investment potentially in
one day, and (3) holding these securities for periods longer than one day could lead to losses
even if the underlying index moves in the anticipated direction. Regulatory organizations,
such as FINRA & SEC, have released alerts stating that inverse and leveraged ETFs that
reset daily typically are not suitable for retail investors who plan to hold them longer than one
day. Managers may hold these products in client accounts for periods of time significantly
greater than one day. Investors with holding periods longer than a day expose themselves to
substantial risk as the holding period returns will deviate from the returns to a leveraged or
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inverse investment in the index. It is possible for an investor in a leveraged ETF to experience
negative returns even when the underlying index has positive returns.
Penny Stock Risks. Generally, Penny Stocks are low-priced shares of small companies that
are not traded on an exchange. Penny Stocks typically trade over-the-counter, such as on
the OTC Bulletin Board or Pink Sheets. Penny Stocks, unlike listed stocks, are not subject to
SEC reporting requirements or the listing standards of stock exchanges. Because of this,
information about the Penny Stock companies can be difficult to find and verify. Penny Stocks
also have lower liquidity as they are traded less frequently. This also leads to higher volatility.
For these reasons, Penny Stocks are considered to be speculative investments and clients
who trade in penny stocks should be prepared for the possibility that they may lose their
entire investment, or an amount in excess of their investment if they purchased Penny Stocks
on margin.
Variable Annuity Risk. A variable annuity is a form of insurance where the seller or issuer
(typically an insurance company) makes a series of future payments to a buyer (annuitant) in
exchange for the immediate payment of a lump sum (single-payment annuity) or a series of
regular payments (regular-payment annuity). The payment stream from the issuer to the
annuitant has an unknown duration based principally upon the date of death of the annuitant.
At this point, the contract will terminate, and the remainder of the funds accumulated are
forfeited unless there are other annuitants or beneficiaries in the contract. Annuities can be
purchased to provide an income during retirement. Unlike fixed annuities that make payments
in fixed amounts or in amounts that increase by a fixed percentage, variable annuities, pay
amounts that vary according to the performance of a specified set of investments, typically
bond and equity mutual funds. Many variable annuities typically impose asset-based sales
charges or surrender charges for withdrawals within a specified period. Variable annuities
may impose a variety of fees and expenses, in addition to sales and surrender charges, such
as mortality and expense risk charges; administrative fees; underlying fund expenses; and
charges for special features, all of which can reduce the return. Earnings in a variable annuity
do not provide all the tax advantages of 401(k)s and other before-tax retirement plans. Once
the investor starts withdrawing money from their variable annuity, earnings are taxed at the
ordinary income rate, rather than at the lower capital gains rates applied to other non-tax-
deferred vehicles which are held for more than one year. Proceeds of most variable annuities
do not receive a "step-up" in cost basis when the owner dies like stocks, bonds and mutual
funds do. Some variable annuities offer "bonus credits." These are usually not free. To fund
them, insurance companies typically impose mortality and expense charges and surrender
charge periods. In an exchange of an existing annuity for a new annuity (so-called 1035
exchanges), the new variable annuity may have a lower contract value and a smaller death
benefit; may impose new surrender charges or increase the period of time for which the
surrender charge applies; may have higher annual fees; and provide another commission for
the broker
Alternative Investments. When appropriate for a client’s objective, risk tolerance and
qualifications, Heritage Haus Wealth recommends the client participate in private issues,
such as single purpose vehicles, funds of funds, private equity, and hedge funds. These are
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usually structured as limited partnerships with differing minimum investments, liquidity, and
fees.
The foregoing list of risk factors does not purport to be a complete enumeration or
explanation of the risks involved in an investment with Heritage Haus Wealth.
Item 9 – Disciplinary Information
Heritage Haus Wealth and its management have not been involved in any criminal or civil
actions, administrative or self-regulatory enforcement proceedings, nor any legal or
disciplinary events that are material to a client’s or prospective client’s evaluation of Heritage
Haus Wealth or the integrity of its management.
Item 10 – Other Financial Industry Activities and Affiliations
Registration as a Broker-Dealer or Broker-Dealer Representative
A.
Neither Heritage Haus Wealth nor its management persons are registered as a broker-dealer
or broker-dealer representative.
B.
Registration as a Futures Commission Merchant, Commodity Pool Operator, or a
Commodity Trading Advisor
Neither Heritage Haus Wealth nor its management persons are registered as futures
commission merchants, commodity pool operators, or a commodity trading advisor.
Relationships Material to this Advisory Business and Possible Conflicts of Interest
C.
Neither Heritage Haus Wealth nor its management persons have any additional material
relationships with this advisory business that would present a possible conflict of interest
other than what may be disclosed above.
Selection of Other Advisors or Managers
D.
Heritage Haus Wealth does not utilize nor select other advisors.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
Code of Ethics
A.
The supervised persons (supervised persons include employees and/or independent
contractors) of Heritage Haus Wealth have committed to a Code of Ethics (“Code”). The
purpose of our Code is to set forth standards of conduct expected of Heritage Haus Wealth
supervised and addresses conflicts that may arise. The Code defines acceptable behavior
for supervised persons of Heritage Haus Wealth. The Code reflects Heritage Haus Wealth
and its supervised persons’ responsibility to act in the best interest of their client.
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One area which the Code addresses is when supervised persons buy or sell securities for
their personal accounts and how to mitigate any conflict of interest with our clients. We do
not allow any supervised persons to use non-public material information for their personal
profit or to use internal research for their personal benefit in conflict with the benefit to our
clients.
Heritage Haus Wealth’s policy prohibits any person from acting upon or otherwise misusing
non-public or inside information. No advisory representative or other supervised person,
officer or director of Heritage Haus Wealth may recommend any transaction in a security or
its derivative to advisory clients or engage in personal securities transactions for a security
or its derivatives if the advisory representative possesses material, non-public information
regarding the security.
Heritage Haus Wealth’s Code is based on the guiding principle that the interests of the client
are our top priority. Heritage Haus Wealth’s officers, directors, advisors, and other supervised
persons have a fiduciary duty to our clients and must diligently perform that duty to maintain
the complete trust and confidence of our clients. When a conflict arises, it is our obligation to
put the client’s interests over the interests of either supervised persons or Heritage Haus
Wealth.
Certain parts of this Code apply to “access” persons. “Access” persons are supervised
persons who have access to non-public information regarding any clients' purchase or sale
of securities, or non-public information regarding the portfolio holdings of any reportable
fund, who are involved in making securities recommendations to clients, or who have access
to such recommendations that are non-public.
Heritage Haus Wealth will provide a copy of the Code of Ethics to any client or prospective
client upon request.
Recommendations Involving Material Financial Interests
B.
Neither Heritage Haus Wealth nor its related persons recommend to clients, or buys or sells
for client accounts, securities in which Heritage Haus Wealth or a related person has a
material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
C.
Interest
Heritage Haus Wealth and its supervised persons may invest in the same securities (or
related securities, e.g., warrants, options or futures) that Heritage Haus Wealth or a
supervised person recommends to clients. In order to mitigate conflicts of interest, such as
frontrunning, Heritage Haus Wealth’s Chief Compliance Officer, or their designee, will no less
than quarterly, review firm and/or personal holdings of its supervised persons. These reviews
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ensure that the personal trading of supervised persons does not disadvantage clients of
Heritage Haus Wealth.
Client Securities Recommendations or Trades and Concurrent Advisory Firm
D.
Securities Transactions and Conflicts of Interest
Heritage Haus Wealth and its supervised persons may recommend securities, or buy or sell
securities for clients’ accounts, at or about the same time, that they also buy or sell the same
securities in their own account(s). Heritage Haus Wealth, for instance, will place trades in an
account in an attempt to earn better than money market rates. In order to mitigate conflicts
of interest, such as frontrunning, Heritage Haus Wealth’s Chief Compliance Officer, or their
designee, will no less than quarterly, review firm and/or personal holdings of its supervised
persons. These reviews ensure that the personal trading of supervised persons does not
disadvantage clients of Heritage Haus Wealth.
Item 12 – Brokerage Practices
Factors Used to Select or Recommending Broker-Dealers
A.
Heritage Haus Wealth requires the use of a specific broker dealer. Heritage Haus Wealth will
select appropriate broker dealers based on a number of factors including but not limited to
their transaction fees, quality of customer service, and reporting ability. Heritage Haus Wealth
relies on the broker-dealer to provide its execution services at the best prices available.
Lower fees for comparable services may be available from other sources. Clients pay for all
custodial fees in addition to the advisory fee charged by Heritage Haus Wealth. Please note
that not all Investment Advisors require their client’s direct brokerage.
1.
Research and Other Soft Dollar Benefits
Heritage Haus Wealth does not receive soft dollar benefits.
2.
Brokerage for Client Referrals
Heritage Haus Wealth does not receive client referrals from any custodian or
third party in exchange for using that broker-dealer or third party.
3.
Directed Brokerage
Heritage Haus Wealth does not allow client directed brokerage.
Investment advisors who manage or supervise client portfolios have a fiduciary obligation of
best execution. The determination of what may constitute best execution and price in the
execution of a securities transaction by a broker-dealer involves several considerations and
is subjective. Factors affecting brokerage selection include the overall direct net economic
result to the portfolios, the efficiency with which the transaction is effected, the ability to
affect the transaction where a large block is involved, the operational facilities of the broker-
dealer, the value of an ongoing relationship with such broker-dealer and the financial strength
and stability of the broker-dealer. Heritage Haus Wealth does not receive any portion of the
trading fees.
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Aggregating Trading for Multiple Client Accounts
B.
When a client authorizes discretionary management, Heritage Haus Wealth is authorized in
its discretion to aggregate purchases and sales and other transactions made for the account
with purchases and sales and transactions in the same securities for other clients of Heritage
Haus Wealth. All clients participating in the aggregated order shall receive an average share
price with all other transactions. If aggregation is not allowed or infeasible and individual
transactions occur (e.g., withdrawal or liquidation requests, odd-lot trades, etc.) an account
may potentially be assessed higher costs or less favorable prices than those where
aggregation has occurred. Heritage Haus Wealth will always attempt to aggregate orders
whenever it has the opportunity to do so.
Item 13 – Review of Accounts
Frequency and Nature of Periodic Review and Who Makes Those Reviews
A.
Account reviews are performed at least annually by Heritage Haus Wealth. Account reviews
are performed more frequently when market conditions dictate. Reviews of client accounts
include, but are not limited to, a review of client documented risk tolerance, adherence to
account objectives, investment time horizon, and suitability criteria, reviewing target
allocations of each asset class to identify if there is an opportunity for rebalancing, and
reviewing accounts for tax loss harvesting opportunities.
Financial plans are updated as requested by the client and pursuant to a new or amended
agreement, Heritage Haus Wealth suggests updating at least annually.
Factors That Will Trigger a Non-Periodic Review of Client Accounts
B.
Other conditions that may trigger a review of clients’ accounts are changes in the tax laws,
new investment information, and changes in a client's own situation.
Content and Frequency of Regular Reports
C.
Clients receive written account statements no less than quarterly for managed accounts.
Account statements are issued by the client’s custodian. Client receives confirmations of
each transaction in account from Custodian and an additional statement during any month in
which a transaction occurs. Heritage Haus Wealth may also send periodic or other event-
inspired reports based on market or portfolio activity. Reports will generally be provided in
electronic format.
Item 14 – Client Referrals and Other Compensation
Economic Benefits from Others
A.
Heritage Haus Wealth does not receive any economic benefits from external sources.
Compensation to Non-Advisory Personnel for Client Referrals
B.
Heritage Haus Wealth does not compensate for client referrals.
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Item 15 – Custody
All assets are held at qualified custodians, which means the custodians provide account
statements directly to clients at least quarterly. Clients are urged to compare the account
statements received directly from their custodians to any documentation or reports prepared
by Heritage Haus Wealth.
Heritage Haus Wealth is deemed to have limited custody solely because advisory fees are
directly deducted from client’s accounts by the custodian on behalf of Heritage Haus Wealth.
Heritage Haus Wealth will obtain written authorization from clients to allow for such
deductions.
Heritage Haus Wealth has limited custody due to having standing letters of authorization
(“SLOA”) to direct third party payments. Heritage Haus Wealth will meet the following seven
conditions when a SLOA has been established with a client to be exempted from the annual
audit requirement:
1. The client provides instructions to the qualified custodian, in writing, that
includes the client’s signature, the third party’s name, and either the third
party’s address or the third party’s account number at a custodian to which the
transfer will be directed.
2. The client authorizes the investment advisor, in writing, either on the qualified
custodian’s form or separately, to direct transfers to the third party either on a
specified schedule or from time to time.
3. The client’s qualified custodian performs appropriate verification of the
instruction, such as a signature review or other method to verify the client’s
authorization and provides a transfer of funds notice to the client promptly
after each transfer.
4. The client has the ability to terminate or change the instruction to the client’s
qualified custodian.
5. The investment advisor has no authority or ability to designate or change the
identity of the third party, the address, or any other information about the third
party contained in the client’s instruction.
6. The investment advisor maintains records showing that the third party is not a
related party of the investment advisor or located at the same address as the
investment advisor.
7. The client’s qualified custodian sends the client, in writing, an initial notice
confirming the instruction and an annual notice reconfirming the instruction.
Heritage Haus Wealth is not affiliated with the custodian. The custodian does not supervise
Heritage Haus Wealth, its employees or activities.
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Item 16 – Investment Discretion
If applicable, client will authorize Heritage Haus Wealth discretionary authority, via the
Advisory Agreement, to determine, without obtaining specific client consent, the securities to
be bought or sold, and the amount of the securities to be bought or sold. If applicable, client
will authorize Heritage Haus Wealth discretionary authority to execute selected investment
program transactions as stated within the Investment Advisory Agreement. If however,
consent for discretion is not given, Heritage Haus Wealth will obtain prior client approval
before executing each transaction.
Heritage Haus Wealth allows clients to place certain restrictions, as outlined in the client’s
Investment Policy Statement or similar document. Such restrictions could include only
allowing purchases of socially conscious investments. These restrictions must be provided
to Heritage Haus Wealth in writing.
The client approves the custodian to be used, and the commission rates paid to the
custodian. Heritage Haus Wealth does not receive any portion of the transaction fees or
commissions paid by the client to the custodian.
Item 17 – Voting Client Securities
Clients will receive proxy voting information directly from the issuer and/or custodian of the
security. Clients will not receive any such proxy voting material from Heritage Haus Wealth.
When assistance on voting proxies is requested by the client, Heritage Haus Wealth will
provide recommendations to the client. However, Heritage Haus Wealth will not have
authority to vote proxies on behalf of the client. If in the future Heritage Haus Wealth
obtains authority to vote proxies, this Brochure will be appropriately amended. Clients may
contact Heritage Haus Wealth at (830) 316-3590 or msrulowitz@heritagehauswp.com.
Item 18 – Financial Information
Balance Sheet
A.
Heritage Haus Wealth does not require nor solicit prepayment of more than $1,200 in fees
per client, six months or more in advance.
Financial Condition
B.
Heritage Haus Wealth nor its management persons have any financial conditions that are
likely to reasonably impair its ability to meet contractual commitments to clients.
Bankruptcy Petitions in Previous Years
C.
Heritage Haus Wealth has not been the subject of a bankruptcy petition in the last ten years.
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SUPERVISED PERSON BROCHURE
Part 2B of Form ADV
Heritage Haus Wealth Partners LLC
Michael Samuel Srulowitz
Physical Address: 1176 N. Business IH 35, New Braunfels, TX 78130
Mailing Address: 146 S. State Highway 46, New Braunfels, TX 78130
Phone: (830) 316-3590
msrulowitz@heritagehauswp.com
www.heritagehauswealth.com
October 5, 2026
This brochure supplement provides information about Michael Samuel Srulowitz and
supplements the Heritage Haus Wealth Partners LLC brochure. You should have received
a copy of that brochure. Please contact Michael Srulowitz, Chief Compliance Officer, if
you did not receive the brochure or if you have any questions about the contents of this
supplement.
Additional information about Michael Srulowitz (CRD# 5497663) is also available on the
SEC’s website at www.adviserinfo.sec.gov.
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Supervised Person Brochure – Michael Samuel Srulowitz
Year of birth: 1978
Item 2 - Educational Background and Business Experience
Educational Background:
● Texas State University, Bachelor of Business Administration in Finance; 2003
Business Experience:
● Heritage Haus Wealth Partners LLC; Co-Founder, CEO, CCO; 7/2026 – Present
● Teamwork Financial Advisors; Investment Advisor Representative; 08/2019 –
07/2026
● First Command Financial Services; Financial Advisor; 02/2008 – 08/2019
Professional Designations:
Enrolled Agent (EA)
An enrolled agent is a person who has earned the privilege of representing taxpayers
before the
Internal Revenue Service (IRS) by either passing a three-part
comprehensive IRS test covering individual and business tax returns, or through
experience as a former IRS employee. Enrolled agent status is the highest credential
the IRS awards. Individuals who obtain this elite status must adhere to ethical
standards and complete 72 hours of continuing education courses every three years.
Enrolled agents, like attorneys and certified public accountants (CPAs), have unlimited
practice rights. This means they are unrestricted as to which taxpayers they can
represent, what types of tax matters they can handle, and which IRA offices they can
represent clients before.
Item 3 - Disciplinary Information
Criminal or Civil Action: None to report
Administrative Proceeding: None to report
Self-Regulatory Proceeding: None to report
Item 4 - Other Business Activities Engaged In
Michael Samuel Srulowitz does not have any outside business activities.
Item 5 - Additional Compensation
Michael Samuel Srulowitz does not receive additional compensation, or performance-based
fees, nor does he receive any additional compensation for performing advisory services other
than what is disclosed in Item 4 of Part 2A.
Item 6 - Supervision
Michael Samuel Srulowitz is the Chief Compliance Officer of Heritage Haus Wealth Partners
LLC and therefore is solely responsible for all supervision and formulation and monitoring of
investment advice offered to Clients. They can be reached using the contact information
provided on the above cover page.
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SUPERVISED PERSON BROCHURE
Part 2B of Form ADV
Heritage Haus Wealth Partners LLC
Michael Francisco Gaona
Physical Address: 1176 N. Business IH 35, New Braunfels, TX 78130
Mailing Address: 146 S. State Highway 46, New Braunfels, TX 78130
Phone: (830) 316-3590
mgaona@heritagehauswp.com
www.heritagehauswealth.com
October 5, 2026
This brochure supplement provides information about Michael Francisco Gaona and
supplements the Heritage Haus Wealth Partners LLC brochure. You should have received
a copy of that brochure. Please contact Michael Srulowitz, Chief Compliance Officer, if
you did not receive the brochure or if you have any questions about the contents of this
supplement.
Additional information about Michael Gaona (CRD# 6742148) is also available on the
SEC’s website at www.adviserinfo.sec.gov.
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Supervised Person Brochure – Michael Francisco Gaona
Year of birth: 1994
Item 2 - Educational Background and Business Experience
Educational Background:
● The University of Texas at San Antonio, Bachelor of Business Administration in
Finance; 2016
Business Experience:
● Heritage Haus Wealth Partners LLC; Co-Founder, Vice President; 07/2026 – Present
● Teamwork Financial Advisors; Investment Advisor Representative; 08/2019 –
07/2026
● First Command Financial Services; Associate Financial Advisor; 01/2017 – 08/2019
Item 3 - Disciplinary Information
Criminal or Civil Action: None to report
Administrative Proceeding: None to report
Self-Regulatory Proceeding: None to report
Item 4 - Other Business Activities Engaged In
Michael Francisco Gaona does not have any outside business activities.
Item 5 - Additional Compensation
Michael Francisco Gaona does not receive additional compensation, or performance-based
fees, nor does he receive any additional compensation for performing advisory services other
than what is disclosed in Item 4 of Part 2A.
Item 6 - Supervision
The Chief Compliance Officer of Heritage Haus Wealth Partners LLC supervises and
monitors the advisory services of Michael Francisco Gaona. The Chief Compliance Officer,
Michael Samuel Srulowitz, can be reached at msrulowitz@heritagehauswp.com or (830) 316-
3590.
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SUPERVISED PERSON BROCHURE
Part 2B of Form ADV
Heritage Haus Wealth Partners LLC
Tanner J. Friesenhahn
Physical Address: 1176 N. Business IH 35, New Braunfels, TX 78130
Mailing Address: 146 S. State Highway 46, New Braunfels, TX 78130
Phone: (830) 316-3590
tfriesenhahn@heritagehauswp.com
www.heritagehauswealth.com
October 5, 2026
This brochure supplement provides information about Tanner J. Friesenhahn and
supplements the Heritage Haus Wealth Partners LLC brochure. You should have received
a copy of that brochure. Please contact Michael Srulowitz, Chief Compliance Officer, if
you did not receive the brochure or if you have any questions about the contents of this
supplement.
Additional information about Tanner J. Friesenhahn (CRD# 7337038) is also available on
the SEC’s website at www.adviserinfo.sec.gov.
26
Supervised Person Brochure – Tanner J. Friesenhahn
Year of birth: 1996
Item 2 - Educational Background and Business Experience
Educational Background:
● Texas State University, Bachelor of Business Administration in Accounting; 2019
Business Experience:
● Heritage Haus Wealth Partners LLC; Lead Advisor; 07/2026 – Present
● Teamwork Financial Advisors; Investment Advisor Representative; 12/2024 –
07/2026
● LPL Financial LLC; Licensed Admin; 12/2022 – 12/2024
● Pontem Financial; Associate Financial Advisor; 02/2021 – 12/2024
● Texas Comptroller of Public Accounts; Auditor 1; 01/2020 – 01/2021
Item 3 - Disciplinary Information
Criminal or Civil Action: None to report
Administrative Proceeding: None to report
Self-Regulatory Proceeding: None to report
Item 4 - Other Business Activities Engaged In
Tanner J. Friesenhahn does not have any outside business activities.
Item 5 - Additional Compensation
Tanner J. Friesenhahn does not receive additional compensation, or performance-based
fees, nor does he receive any additional compensation for performing advisory services other
than what is disclosed in Item 4 of Part 2A.
Item 6 - Supervision
The Chief Compliance Officer of Heritage Haus Wealth Partners LLC supervises and
monitors the advisory services of Tanner J. Friesenhahn. The Chief Compliance Officer,
Michael Samuel Srulowitz, can be reached at msrulowitz@heritagehauswp.com or (830) 316-
3590.
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