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FORM ADV PART 2A
Greg Jennings, LLC (CRD 341031), brochure dated October 1, 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
Ives Hill Wealth Management
5789 Widewaters Parkway
DeWitt, NY 13214
Form ADV Part 2A – Firm Brochure
Phone: (315) 446-8720
Dated October 1, 2026
This Brochure provides information about the qualifications and business practices of Greg Jennings, LLC d/b/a
Ives Hill Wealth Management “Ives Hill”. If you have any questions about the contents of this Brochure, please
contact us at Phone: (315) 446-8720. 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.
Ives Hill Wealth Management is registered as an investment adviser with the United States Securities and
Exchange Commission. Registration of an investment adviser does not imply any level of skill or training.
information about
Ives Hill Wealth Management
is available on the SEC’s website at
Additional
www.adviserinfo.sec.gov which can be found using the firm’s identification number 341031.
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Item 2: Material Changes
Since the first filing of Form ADV Part 2A for Ives Hill Wealth Management, dated May 20, 2026, there have been
no material changes. Please note, this item only discusses changes we consider material and not all changes
made.
Contents
Item 1: Cover Page .................................................................................................................................................. 1
Item 3: Table of Contents
Item 2: Material Changes ........................................................................................................................................ 2
Item 3: Table of Contents ....................................................................................................................................... 2
Item 4: Advisory Business ....................................................................................................................................... 3
Item 5: Fees and Compensation ............................................................................................................................. 4
Item 6: Performance-Based Fees and Side-By-Side Management ......................................................................... 5
Item 7: Types of Clients ........................................................................................................................................... 5
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................................................... 5
Item 9: Disciplinary Information ............................................................................................................................. 7
Item 10: Other Financial Industry Activities and Affiliations .................................................................................. 8
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 8
Item 12: Brokerage Practices ................................................................................................................................ 10
Item 13: Review of Accounts ................................................................................................................................ 12
Item 14: Client Referrals and Other Compensation ............................................................................................. 13
Item 15: Custody ................................................................................................................................................... 13
Item 16: Investment Discretion ............................................................................................................................ 13
Item 17: Voting Client Securities .......................................................................................................................... 13
Item 18: Financial Information ............................................................................................................................. 14
Privacy Notice ....................................................................................................................................................... 15
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Description of Advisory Firm
Item 4: Advisory Business
Greg Jennings, LLC d/b/a Ives Hill Wealth Management “Ives Hill” is registered as an investment adviser with
the U.S. Securities and Exchange Commission. We were founded in December 2018 but did not engage in
investment advisor activities until March 2026. Gregory W. Jennings owns one hundred percent (100%) of the
equity in Ives Hill Wealth Management. As of July 31, 2026, we manage $183,051,483 on a discretionary basis.
Types of Advisory Services
Investment Management Services
Clients are provided with an evaluation of their current financial model based upon a review of their investment
holdings, income needs, and estate planning. Investments are reviewed for their performance and suitability.
Investments are bought and sold based upon this analysis.
Client Tailored Services and Client Imposed Restrictions
We offer the same suite of services to all of our clients. However, specific client services are dependent upon a
client’s current goals and situation (income, tax levels, and risk tolerance levels) and is used to construct a client
specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets.
Wrap Fee Programs
We do not participate in wrap fee programs.
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Investment Management Services
Item 5: Fees and Compensation
Our standard advisory fee is based on the market value of the assets under management and is calculated as
follows:
Account Value
Annual Advisory Fee
1.25%
$500,000 and under
1.00%
$500,001 - $1,000,000
¾ of 1.00%
$1,000,001 - $2,000,000
½ of 1.00%
$2,000,001 and Above
The annual fees are paid in arrears on a quarterly basis. The advisory fee is a blended fee and is calculated by
assessing the percentage rates using the predefined levels of assets as shown in the above chart, resulting in a
combined weighted fee. For example, an account valued at $3,000,000 would pay an effective fee of 0.79% with
the annual fee of $23,750.00. The quarterly fee is determined by the following calculation: (($500,000 x 1.25%)
+ ($500,000 x1.00%) + ($1,000,000 x 0.75) + ($1,000,000 x 0.50)) ÷ 4 = $5,937.50. No increase in the annual fee
shall be effective without agreement from the client by signing a new agreement or amendment to their current
advisory agreement.
Advisory fees are directly debited from client accounts. Accounts initiated or terminated during a billing period
will be charged a pro-rated fee based on the amount of time remaining in the billing period. An account may be
terminated with written notice at any time. Since fees are paid in arrears, no rebate will be needed upon
termination of the account.
Hourly Fee
When services are performed on an hourly basis, the rate will be $250.00 per hour. In the event of early
termination by client, any fees for the hours already worked will be due.
Other Types of Fees and Expenses
Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses that
may be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, and other third
parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds
and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus.
Such charges, fees and commissions are exclusive of and in addition to our fee, and we shall not receive any
portion of these commissions, fees, and costs.
Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for client’s
transactions and determining the reasonableness of their compensation (e.g., commissions).
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We do not accept compensation for the sale of securities or other investment products including asset-based
sales charges or service fees from the sale of mutual funds.
We do not offer performance-based fees nor does Ives Hill Wealth Management engage in side by side
management.
Item 6: Performance-Based Fees and Side-By-
Side Management
Item 7: Types of Clients
Individuals, high net worth, trusts, estates, corporations and other business entities. We have a minimum
account requirement of $100,000, which may be waived at our discretion. Accounts may be adjusted based
upon individual circumstances. Accounts to be managed are discretionary.
Our primary methods of investment analysis are fundamental and technical analysis.
Item 8: Methods of Analysis, Investment
Strategies and Risk of Loss
Fundamental analysis involves analyzing individual companies and their industry groups, such as a company’s
financial statements, details regarding the company’s product line, the experience, and expertise of the
company’s management, and the outlook for the company’s industry. The resulting data is used to measure the
true value of the company’s stock compared to the current market value. The risk of fundamental analysis is
that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings,
which may be the basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing
fundamental analysis may not result in favorable performance.
Technical analysis involves using chart patterns, momentum, volume, and relative strength to pick sectors that
may outperform market indices. However, there is no assurance of accurate forecasts or that trends will
develop in the markets we follow. In the past, there have been periods without discernible trends and similar
periods will presumably occur in the future. Even where major trends develop, outside factors like government
intervention could potentially shorten them.
Furthermore, one limitation of technical analysis is that it requires price movement data, which can translate
into price trends sufficient to dictate a market entry or exit decision. In a trendless or erratic market, a technical
method may fail to identify trends requiring action. In addition, technical methods may overreact to minor price
movements, establishing positions contrary to overall price trends, which may result in losses. Finally, a technical
trading method may underperform other trading methods when fundamental factors dominate price moves
within a given market.
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Material Risks Involved
All investing strategies we offer involve risk and may result in a loss of your original investment which you
should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities and any other
investment or security. Material risks associated with our investment strategies are listed below.
Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of
a general market decline, reducing the value of the investment regardless of the success of the issuer’s
operations or its financial condition.
Strategy Risk: The adviser’s investment strategies and/or investment techniques may not work as intended.
Small and Medium Cap Company Risk: Securities of companies with small and micro market capitalizations are
often more volatile and less liquid than investments in larger companies. Small and medium cap companies may
face a greater risk of business failure, which could increase the volatility of the client’s portfolio.
Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A
high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result
in the distribution of additional capital gains for tax purposes. These factors may negatively affect the account’s
performance.
Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times be
more volatile than at other times. Under certain market conditions we may be unable to sell or liquidate
investments at prices we consider reasonable or favorable or find buyers at any price.
Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors or types
of investment. From time to time these strategies may be subject to greater risks of adverse developments in
such areas of focus than a strategy that is more broadly diversified across a wider variety of investments.
Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall
below par value or the principal investment. The opposite is also generally true: bond prices generally rise when
interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price
changes. Most other investments are also sensitive to the level and direction of interest rates.
Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the
securities’ claim on the issuer’s assets and finances.
Inflation: Inflation may erode the buying-power of your investment portfolio, even if the dollar value of your
investments remains the same.
Risks Associated with Securities
Apart from the general risks outlined above which apply to all types of investments, specific securities may have
other risks.
Commercial Paper is, in most cases, an unsecured promissory note that is issued with a maturity of 270 days or
less. Being unsecured the risk to the investor is that the issuer may default.
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Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or
restructuring could lose all value. A slower-growth or recessionary economic environment could have an
adverse effect on the price of all stocks.
Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and
repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively,
investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest, but
rather are priced at a discount from their face values and their values accrete over time to face value at maturity.
The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and
maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest
rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk.
Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the
banking industry. Banks and other financial institutions are greatly affected by interest rates and may be
adversely affected by downturns in the U.S. and foreign economies or changes in banking regulations.
Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the
construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds.
However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax
return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal
bonds carries the same general risks as investing in bonds in general. Those risks include interest rate risk,
reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk and liquidity and valuation risk.
Exchange Trade Funds (ETF) and Mutual Funds bear additional expenses based on their pro rata share of the
ETFs or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of
owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual
fund holds, in addition to the risks linked to the structure, management and liquidity of the ETF or mutual fund
itself. You will also incur brokerage costs when purchasing ETFs or mutual funds. ETFs and mutual funds are also
subject to basis risk, the risk of the ETF’s or mutual fund’s performance diverging from the benchmark.
Criminal or Civil Actions
Item 9: Disciplinary Information
Ives Hill Wealth Management and its management have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
Ives Hill Wealth Management and its management have not been involved in administrative enforcement
proceedings.
Self-Regulatory Organization Enforcement Proceedings
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Ives Hill Wealth Management and its management have not been involved in legal or disciplinary events that
are material to a client’s or prospective client’s evaluation of Ives Hill Wealth Management or the integrity of its
management.
No Ives Hill Wealth Management employee is registered, or has an application pending to register, as a broker-
dealer or a registered representative of a broker-dealer.
Item 10: Other Financial Industry Activities and
Affiliations
No Ives Hill Wealth Management employee is registered, or has an application pending to register, as a futures
commission merchant, commodity pool operator or a commodity trading advisor.
Ives Hill Wealth Management only receives compensation directly from clients. We do not receive
compensation from any outside source. We do not have any conflicts of interest with any outside party.
Item 11: Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading
As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best interests of
each client. Our clients entrust us with their funds and personal information, which in turn places a high standard
on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the
expected basis of all of our dealings.
Code of Ethics Description
This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its
specific provisions will not shield associated persons from liability for personal trading or other conduct that
violates a fiduciary duty to advisory clients. A summary of the Code of Ethics' Principles is outlined below.
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Integrity - Associated persons shall offer and provide professional services with integrity.
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Objectivity - Associated persons shall be objective in providing professional services to clients.
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Competence - Associated persons shall provide services to clients competently and maintain the
necessary knowledge and skill to continue to do so in those areas in which they are engaged.
•
Fairness - Associated persons shall perform professional services in a manner that is fair and reasonable
to clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such
services.
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•
Confidentiality - Associated persons shall not disclose confidential client information without the specific
consent of the client unless in response to proper legal process, or as required by law.
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Professionalism - Associated persons’ conduct in all matter shall reflect credit of the profession.
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Diligence - Associated persons shall act diligently in providing professional services.
We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all access
persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our firm will
provide of copy of its Code of Ethics to any client or prospective client upon request.
Investment Recommendations Involving a Material Financial Interest and Conflicts
of Interest
Neither our firm, its associates or any related person is authorized to recommend to a client, or effect a
transaction for a client, involving any security in which our firm or a related person has a material financial
interest, such as in the capacity as an underwriter, adviser to the issuer, etc.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
Our firm and its “related persons” may buy or sell securities similar to, or different from, those we recommend
to clients for their accounts. Our policy is designed to assure that the personal securities transactions, activities
and interests of the employees of our firm will not interfere with (i) making decisions in the best interest of
advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for
their own accounts. Nonetheless, because the Code of Ethics in some circumstances would permit employees
to invest in the same securities as clients, there is a possibility that employees might benefit from market activity
by a client in a security held by an employee. In an effort to reduce or eliminate certain conflicts of interest
involving the firm or personal trading, our policy may require that we restrict or prohibit associates’ transactions
in specific reportable securities transactions. Any exceptions or trading pre-clearance must be approved by the
firm principal in advance of the transaction in an account, and we maintain the required personal securities
transaction records per regulation.
Trading Securities at/Around the Same Time as Client’s Securities
From time to time, our firm or its “related persons” may buy or sell securities for themselves at or around the
same time as clients. We will not trade non-mutual fund securities prior to the same security for clients on the
same day.
Investment Advice Relating to Retirement Accounts
When we provide investment advice to you regarding your retirement plan account or individual retirement
account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or
the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make
money creates some conflicts with your interests, so we operate under a special rule that requires us to act in
your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice).
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• Never put our financial interests ahead of yours when making recommendations (give loyal advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that we give advice that is in your best interest.
• Charge no more than is reasonable for our services.
• Give you basic information about conflicts of interest.
In addition, and as required by this rule, we provide information regarding the services that we provide to you,
and any material conflicts of interest, in this brochure and in your client agreement.
Factors Used to Select Custodians and/or Broker-Dealers
Item 12: Brokerage Practices
Ives Hill Wealth Management does not have any affiliation with broker-dealers. Specific custodian
recommendations are made to client based on their need for such services. We recommend custodians based
on the reputation and services provided by the firm.
In recommending custodians, we have an obligation to seek the “best execution” of transactions in Client
accounts. The determinative factor in the analysis of best execution is not the lowest possible commission cost,
but whether the transaction represents the best qualitative execution, taking into consideration the full range
of the custodian’s services. The factors we consider when evaluating a custodian for best execution include,
without limitation, the custodian’s:
• Combination of transaction execution services and asset custody services (generally without a separate
fee for custody);
• Capability to execute, clear, and settle trades (buy and sell securities for your account);
• Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill
payment, etc.);
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs),
etc.);
• Availability of investment research and tools that assist us in making investment decisions;
• Quality of services;
• Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.)
and willingness to negotiate the prices;
• Reputation, financial strength, security and stability;
• Prior service to us and our clients.
With this in consideration, our firm recommends Charles Schwab & Co., Inc., a registered broker-dealer, member
FINRA and SIPC (“Schwab”). We are not affiliated with Schwab. The Client will ultimately make the final decision
of the custodian to be used to hold the Client’s investments by signing the selected custodian’s account opening
documentation.
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1. Research and Other Soft-Dollar Benefits
However, as a result of being on their institutional platform, Schwab may provide us with certain services and
products that may benefit us. All such soft dollar benefits are consistent with the safe harbor contained in
Section 28(e) of the Securities Exchange Act of 1934, as amended.
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us. They
provide our Clients and us with access to their institutional brokerage services (trading, custody, reporting and
related services), many of which are not typically available to Schwab retail customers. Schwab also makes
available various support services. Some of those services help us manage or administer our Clients’ accounts,
while others help us manage and grow our business. Schwab’s support services are generally available on an
unsolicited basis (we don’t have to request them) and at no charge to us. The benefits received by advisor or its
personnel do not depend on the number of brokerage transactions directed to Schwab. As part of its fiduciary
duties to Clients, advisor at all times must put the interests of its Clients first. Clients should be aware, however,
that the receipt of economic benefits by advisor or its related persons in and of itself creates a potential conflict
of interest and may indirectly influence the advisor’s choice of Schwab for custody and brokerage services. This
conflict of interest is mitigated as advisor regularly reviews the factors used to select custodians to ensure our
recommendation is appropriate. Following is a more detailed description of Schwab’s support services:
1. Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client assets. The investment
products available through Schwab include some to which we might not otherwise have access or that
would require a significantly higher minimum initial investment by our Clients. Schwab’s services
described in this paragraph generally benefit you and your account.
2. Services that may not directly benefit you. Schwab also makes available to us other products and services
that benefit us but may not directly benefit you or your account. These products and services assist us
in managing and administering our Clients’ accounts. They include investment research, both Schwab’s
own and that of third parties. We may use this research to service all or a substantial number of our
Clients’ accounts, including accounts not maintained at Schwab. In addition to investment research,
Schwab also makes available software and other technology that:
o Provide access to Client account data (such as duplicate trade confirmations and account
statements)
o Facilitate trade execution and allocate aggregated trade orders for multiple Client accounts
o Provide pricing and other market data
o Facilitate payment of our fees from our Clients’ accounts
o Assist with back-office functions, recordkeeping, and Client reporting
3. Services that generally benefit only us. Schwab also offers other services intended to help us manage
and further develop our business enterprise. These services include:
o Educational conferences and events
o Consulting on technology, compliance, legal, and business needs
o Publications and conferences on practice management and business succession
4. Your brokerage and custody costs. For our Clients’ accounts that Schwab maintains, Schwab generally
does not charge you separately for custody services but is compensated by charging you commissions
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or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for
example, many mutual funds and ETFs) may not incur Schwab commissions or transaction fees.
2. Brokerage for Client Referrals
We receive no referrals from a custodian, broker-dealer or third party in exchange for using that custodian,
broker-dealer or third party.
3. Clients Directing Which Broker-Dealer/Custodian to Use
We do not allow clients to direct us to use a specific broker-dealer to execute transactions. Clients must use our
recommended custodian (broker-dealer). Not all investment advisers require their clients to direct brokerage.
By requiring clients to use our specific custodian, we may be unable to achieve most favorable execution of
client transaction and that this may cost clients’ money over using a lower-cost custodian.
Aggregating (Block) Trading for Multiple Client Accounts
Generally, we combine multiple orders for shares of the same securities purchased for advisory accounts we
manage (this practice is commonly referred to as “block trading”). We will then distribute a portion of the shares
to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically
proportionate to the size of the account, but it is not based on account performance or the amount or structure
of management fees. Subject to our discretion, regarding particular circumstances and market conditions, when
we combine orders, each participating account pays an average price per share for all transactions and pays a
proportionate share of all transaction costs. Accounts owned by our firm or persons associated with our firm
may participate in block trading with your accounts; however, they will not be given preferential treatment.
Item 13: Review of Accounts
Client accounts with the Investment Management Service will be reviewed regularly on a quarterly basis by
Gregory W. Jennings, Managing Member and Brian Jennings, Investment Adviser Representative. The account
is reviewed with regards to the client’s investment policies and risk tolerance levels. Events that may trigger a
special review would be unusual performance, addition or deletions of client imposed restrictions, excessive
draw-down, volatility in performance, or buy and sell decisions from the firm or per client's needs.
Clients will receive trade confirmations from the broker(s) for each transaction in their accounts as well as
monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity
in the accounts, such as receipt of dividends and interest.
Ives Hill Wealth Management will provide written and/or electronic reports to investment management clients
on a quarterly basis. We urge clients to compare these reports against the account statements they receive from
their custodian.
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We do not receive any economic benefit, directly or indirectly from any third party for advice rendered to our
clients. Nor do we directly or indirectly compensate any person who is not advisory personnel for client referrals.
Item 14: Client Referrals and Other
Compensation
Item 15: Custody
Ives Hill Wealth Management does not accept physical custody of client funds, however it is deemed to have
limited custody solely with its ability to withdraw fees from clients’ accounts. Clients should receive at least
quarterly statements from the broker-dealer, bank or other qualified custodian that holds and maintains client's
investment assets. We urge you to carefully review such statements and compare such official custodial records
to the account statements or reports that we may provide to you. Our statements or reports may vary from
custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain
securities.
Item 16: Investment Discretion
For those client accounts where we provide investment management services, we maintain discretion over
client accounts with respect to securities to be bought and sold and the amount of securities to be bought and
sold. Investment discretion is explained to clients in detail when an advisory relationship has commenced. At
the start of the advisory relationship, the client will execute a Limited Power of Attorney, which will grant our
firm discretion over the account. Additionally, the discretionary relationship will be outlined in the advisory
contract and signed by the client. Clients may impose reasonable restrictions on investing in certain securities,
types of securities, or industry sectors.
Item 17: Voting Client Securities
We do not vote client proxies. Therefore, clients maintain exclusive responsibility for voting proxies. The client
shall instruct the client’s qualified custodian to forward to the client copies of all proxies and shareholder
communications relating to the client’s investment assets. If the client would like our opinion on a particular
proxy vote, they may contact us at the number listed on the cover of this brochure.
In most cases, you will receive proxy materials directly from the account custodian. However, in the event we
were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless
you have authorized our firm to contact you by electronic mail, in which case, we would forward you any
electronic solicitation to vote proxies.
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Item 18: Financial Information
Registered investment advisers are required in this Item to provide you with certain financial information or
disclosures about our financial condition. We have no financial commitment that impairs our ability to meet
contractual and fiduciary commitments to clients, and we have not been the subject of bankruptcy proceedings.
We do not have custody of client funds or securities, nor do we require the prepayment of fees of more than
$1,200 for SEC firms or more in advance.
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WHAT DOES IVES HILL WEALTH MANAGEMENT DO WITH YOUR
PERSONAL INFORMATION?
Privacy Notice
FACTS
Why?
Registered investment advisers choose how they share your personal information. Federal law
gives clients the right to limit some but not all sharing. Federal law also requires us to tell you
h o w we collect, share, and protect your personal information. Please read this notice carefully
to understand what we do.
What?
The types of personal information we collect, and share depend on the product or service you
have with us. This information can include:
Information you provide in the subscription documents and other forms (including
name, address, social security number, date of birth, income and other financial-
related information); and
Data about your transactions with us (such as the types of investments you have
made and your account status).
How?
All financial companies need to share clients’ personal information to run their everyday
business. In the section below, we list the reasons financial companies can share their clients’
personal information; the reasons Ives Hill Management chooses to share; and whether you can
limit this sharing.
Reasons we can share your personal information
For our everyday business purposes— to process your transactions, maintain your accounts (for example we may
share with our third-party service providers that perform services on our behalf or on your behalf, such as accountants,
attorneys, consultants, clearing and custodial firms, and technology companies, respond to court orders and legal
investigations, or report to credit bureaus.
For Marketing purposes— to offer our products and services to you
How do we protect your information?
To safeguard your personal information from unauthorized access and use, we maintain physical, procedural and
electronic safeguards. These include computer safeguards such as passwords, secured files and buildings.
Our employees are advised about Ives Hill Wealth Management's need to respect the confidentiality of each client’s
non-public personal information. We train our employees on their responsibilities.
We require third parties that assist in providing our services to you to protect the personal information they receive.
This includes contractual language in our third-party agreements.
Other important information
We will send you notice of our Privacy Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise our Privacy Policy and will provide you with a revised policy if the changes materially alter
the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal
information other than as described in this notice unless we first notify you and provide you with an opportunity to
prevent the information sharing.
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