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H Financial Management
Disclosure Brochure
3/24/2026
Item 1 – Cover Page
CRD#148209
This brochure provides information about the qualifications and business practices of H Financial
Management (“HFM” or “Adviser”).
If you have any questions about the contents of this brochure, please contact us at (724) 745-9406.
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.
H Financial Management is a Registered Investment Adviser. Registration as an Investment Adviser does
not imply any level of skill or training. This disclosure document is designed to grant current clients as
well as potential clients the opportunity to carefully read and establish an understanding of the various
investment advisory services that are offered and the respective fees and expenses of those services. The
information contained in this document is important to the conduct of both parties entering an advisory
contract. While investment advisers have a fiduciary duty to put the needs of clients before their own,
clients likewise have a duty to investigate and maintain a basic understanding of the services offered by
the Adviser. We hope this document serves as a leading educational tool to aid clients and prospective
clients in understanding how H Financial Management conducts investment advisory services.
H Financial is located in an exclusive business park development located 20 minutes by interstate outside
of Pittsburgh, PA. Our clients appreciate our easily accessible and exclusive location on the sprawling
Southpointe campus located on Interstate 79 at the Southpointe exit (Exit 48) near the border of
Washington County and Allegheny County.
H Financial Management
400 Southpointe Blvd., Suite 420
Canonsburg, PA 15317
(724) 745-9406
www.hfinancialmanagement.com
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Item 2- Material Changes
H Financial Management (“HFM”) has not made any material changes to H Financial Management’s
(“HFM”) Part 2A Brochure since this year’s Annual Amendment filing on January 6, 2025.
ANY QUESTIONS: HFM’s Chief Compliance Officer, Kent D. Aloia, CFP®, AIF®, remains available to
address any questions regarding this Part 2A, including the disclosure additions and enhancements
below.
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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 – Investment Advisory Services………………………………………………………………………….. 4
Item 5 – Fee Schedule ………………………………………………………………………………….……………… 9
Item 6 – Performance Based Fee and Side-by-Side Management ……………………………….. 11
Item 7 – Types of Clients ……………………………………………………………………………………………… 11
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ………………………… 12
Item 9 – Disciplinary Information ………………………………………………………………………………… 15
Item 10 – Other Financial Industry Activities and Affiliations ………………………………………. 15
Item 11 – Code of Ethics (Participation or Interest in Client Transactions and Personal Trading) …… 15
Item 12 – Brokerage Practices …………………………………………………………………………………….. 16
Item 13 – Review of Accounts ……………………………………………………………………………………… 17
Item 14 – Client Referrals and Other Compensation …………………………………………………… 17
Item 15 – Custody ……………………………………………………………………………………………………….. 18
Item 16 – Investment Discretion …………………………………………………………………………………. 18
Item 17 – Voting Client Securities ………………………………………………………………………………. 18
Item 18 – Financial Information ………………………………………………………………………………….. 19
Privacy Statement ………………………………………………………………………………………………………. 20
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Item 4 – Investment Advisory Services
H Financial Management was founded in 1981 and is owned by Hoge Financial Holdings, LLC. The firm is
principally owned by Hoge Legacy, LLC and Merchant Wealth Partners, LLC. Garrett Hoge is the CEO and
managing partner.
H Financial has 1,678 advisory accounts with $621,882,966 in Assets under Management as of 12/31/2025
(1,402 discretionary accounts totaling $569,640,808, 276 non-discretionary accounts totaling
$52,242,158).
The client can engage HFM to provide discretionary and/or non-discretionary investment advisory
services to individuals, families, and businesses. Before engaging HFM to provide investment advisory
services, clients are required to enter into an agreement with HFM setting forth the terms and conditions
of the engagement, describing the scope of the services to be provided, and the fees that a client will
incur (see fee schedule at Item 5 below). To the extent requested by an individual client, HFM will
generally provide financial planning and consulting services. In the event that the client requires
extraordinary planning or consultation services HFM may determine to charge a client for such
additional services pursuant to a stand-alone written agreement (see Limitations below). Before
providing investment advisory services, HFM will ascertain the client’s investment objective(s). HFM will
then allocate (or recommend that the client allocate) the portfolio consistent with the designated
investment objective(s).
Miscellaneous
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the
extent requested by a client, HFM will usually provide financial planning and related consulting services
regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. HFM will
generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below, but may,
depending upon the amount of assets under management and/or scope of the services to be provided,
determine to charge a mutually agreed upon fee per the terms and conditions of a separate written
agreement. Please Note. HFM believes that it is important for the client to address financial planning
issues on an ongoing basis. HFM’s advisory fee, as set forth at Item 5 below, will remain the same
regardless of whether or not the client determines to address financial planning issues with HFM. Please
Also Note: We do not serve as an attorney or accountant, and no portion of our services should be
construed as same. Accordingly, we do not prepare estate planning documents or tax returns. To the
extent requested by a client, we may recommend the services of other professionals for certain non-
investment implementation purpose (i.e. attorneys, accountants, insurance, etc.), including certain HFM’s
representatives, in their separate individual capacities as representative of Osaic Wealth, Inc. (“Osaic”),
an SEC registered and FINRA member broker-dealer, and as licensed insurance agents. The client is under
no obligation to engage the services of any such recommended professional. The client retains absolute
discretion over all such implementation decisions and is free to accept or reject any recommendation
from HFM and/or its representatives. Please Note: If the client engages any recommended unaffiliated
professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek
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recourse exclusively from and against the engaged professional. At all times, the engaged licensed
professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not HFM, shall be responsible for the
quality and competency of the services provided. Please Also Note-Conflict of Interest: The
recommendation by HFM that a client purchase a securities or insurance commission product from HFM’s
representatives in their separate individual capacities as representatives of Osaic and/or as an insurance
agents, presents a conflict of interest, as the receipt of commissions may provide an incentive to
recommend investment products based on commissions to be received, rather than on a particular
client’s need. No client is under any obligation to purchase any securities or insurance commission
products from HFM’s representatives. Clients are reminded that they may purchase securities and
insurance products recommended by HFM through other, non-affiliated broker-dealers and/or insurance
agencies. HFM’s Chief Compliance Officer, Kent D. Aloia, CFP® AIF®, remains available to address any
questions that a client or prospective client may have regarding the above conflict of interest.
Participant Directed Retirement Plans. HFM may also provide investment advisory and consulting
services to participant directed retirement plans per the terms and conditions of a written agreement
between HFM and the plan. For such engagements, HFM shall assist the Plan sponsor with the selection
of an investment platform from which Plan participants shall make their respective investment choices
(which may include investment strategies devised and managed by HFM), and, to the extent engaged to
do so, may also provide corresponding education to assist the participants with their decision-making
process.
Please Note: Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving
an employer typically has four options regarding an existing retirement plan (and may engage in a
combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll
over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to
an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon
the client’s age, result in adverse tax consequences). If HFM recommends that a client roll over their
retirement plan assets into an account to be managed by HFM, such a recommendation creates a conflict
of interest if HFM will earn new (or increase its current) compensation as a result of the rollover. If HFM
provides a recommendation as to whether a client should engage in a rollover or not (whether it is from
an employer’s plan or an existing IRA), HFM is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets
to an account managed by HFM, whether it is from an employer’s plan or an existing IRA. HFM’s Chief
Compliance Officer, Kent Aloia, remains available to address any questions that a client or prospective
client may have regarding the potential for conflict of interest presented by such rollover
recommendation.
Please Note: Non-Discretionary Service Limitations. Clients that engage HFM on a non-discretionary
investment advisory basis must be willing to accept that HFM cannot affect any account transactions
without obtaining prior consent to any such transaction(s) from the client. Therefore, in the event that
HFM would like to make a transaction for a client's account (including in the event of an individual holding
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or general market correction), and the client is unavailable, HFM will be unable to effect the account
transaction(s) without first obtaining the client’s consent.
Please Note-Use of Mutual Funds and Exchange Traded Funds: Most mutual and exchange traded funds
are available directly to the public. Thus, a prospective client can obtain many of the mutual and exchange
traded funds that may be recommended and/or utilized by HFM independent of engaging HFM as an
investment adviser. However, if a prospective client determines to do so, he/she will not receive HFM’s
initial and ongoing investment advisory services. Separate Fees: All mutual and exchange traded funds
impose fees at the fund level (e.g. management fees and other fund expenses). All mutual fund and
exchange traded fund fees are separate from, and in addition to, HFM’s wealth management fee as
described at Item 5 below. HFM’s Chief Compliance Officer, Kent D. Aloia, CFP® AIF®, remains available
to address any questions that a client or prospective client may have regarding the above.
Individual Equity Portfolios. HFM primarily purchases mutual funds and exchange traded funds for its
client accounts. In limited situations, HFM, upon client consent, may determine to purchase individual
equites for certain client portfolios in conjunction with the consulting services provided by William Blair,
a nationally recognized investment management firm.
Independent Managers. The HFM may allocate (or recommend that the client allocate) a portion of the
client’s investment assets among unaffiliated independent investment managers in accordance with the
client’s designated investment objective(s). In such situations, the Independent Manager[s] shall have
day-to- day responsibility for the active discretionary management of the allocated assets. HFM shall
continue to render investment supervisory services to the client relative to the ongoing monitoring and
review of account performance, asset allocation and client investment objectives. Factors that HFM shall
consider in recommending Independent Manager[s] include the client’s designated investment
objective(s), management style, performance, reputation, financial strength, reporting, pricing, and
research. Please Note. The investment management fee charged by the Independent Manager[s] is
separate from, and in addition to, HFM’s investment advisory fee disclosed at Item 5 below.
Portfolio Activity. HFM has a fiduciary duty to provide services consistent with the client’s best interest.
As part of its investment advisory services, HFM will review client portfolios on an ongoing basis to
determine if any changes are necessary based upon various factors, including, but not limited to,
investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a
change in the client’s investment objective. Based upon these factors, there may be extended periods of
time when HFM determines that changes to a client’s portfolio are neither necessary nor prudent. Of
course, as indicated below, there can be no assurance that investment decisions made by HFM will be
profitable or equal any specific performance level(s). Clients are still subject to the fees described in Item
5 below, even during periods of account inactivity.
Business Consulting Services. HFM can also be engaged to provide business-related consulting services
per the terms and conditions of a written agreement between HFM and the client. The fee, which is
negotiable, shall depend upon the scope of the services required and the professional(s) providing the
service(s).
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Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend
a broker-dealer/custodian for client accounts, HFM generally recommends that Fidelity serve as the
broker-dealer/custodian for client investment management assets. Broker-dealers such as Fidelity charge
brokerage commissions, transaction, and/or other type fees for affecting certain types of securities
transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs
charged for fixed income transactions, etc.). The types of securities for which transaction fees,
commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the
broker-dealer/custodian. While certain custodians, including Fidelity, generally (with the potential
exception for large orders) do not currently charge fees for individual equity transactions (including ETFs),
others do. Please Note: there can be no assurance that Fidelity will not change its transaction fee pricing
in the future. The above fees/charges are in addition to HFM’s investment advisory fee at Item 5 below.
HFM does not receive any portion of these fees/charges.
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account
transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated
sweep account. The yield on the sweep account will generally be lower than those available for other
money market accounts. When this occurs, to help mitigate the corresponding yield dispersion, HFM shall
(usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market
fund (or other type security) available on the custodian’s platform, unless HFM reasonably anticipates
that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional
investments for the client’s account. Exceptions and/or modifications can and will occur with respect to
all or a portion of the cash balances for various reasons, including, but not limited to the amount of
dispersion between the sweep account and a money market fund, the size of the cash balance, an
indication from the client of an imminent need for such cash, or the client has a demonstrated history of
writing checks from the account. Please Note: The above does not apply to the cash component
maintained within a HFM actively managed investment strategy (the cash balances for which shall
generally remain in the custodian designated cash sweep account), an indication from the client of a need
for access to such cash, assets allocated to an unaffiliated investment manager, and cash balances
maintained for fee billing purposes. Please Also Note: The client shall remain exclusively responsible for
yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in
any HFM unmanaged accounts.
Please Note: Cash Positions. HFM continues to treat cash as an asset class. As such, unless determined
to the contrary by HFM, all cash positions (money markets, etc.) shall continue to be included as part of
assets under management for purposes of calculating HFM’s advisory fee. At any specific point in time,
depending upon perceived or anticipated market conditions/events (there being no guarantee that such
anticipated market conditions/events will occur), HFM may maintain cash positions for defensive
purposes. In addition, while assets are maintained in cash, such amounts could miss market advances.
Depending upon current yields, at any point in time, HFM’s advisory fee could exceed the interest paid by
the client’s money market fund.
EMoney. In conjunction with the services provided by EMoney, HFM may also provide access to account
aggregation services, which can incorporate all of the client’s investment assets, including those
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investment assets that are not part of the assets that we manage (the “Excluded Assets”). The client
and/or their other advisers that maintain trading authority, and not us, shall be exclusively responsible
for the investment performance of the Excluded Assets. In addition, EMoney will also provide access to
other types of information, including financial planning concepts, which should not, in any manner
whatsoever, be construed as services, advice or recommendations provided by HFM. HFM does not
provide investment management, monitoring or implementation services for the Excluded Assets. The
client may engage HFM to provide investment management services for the Excluded Assets pursuant to
the terms and conditions of the Investment Advisory Agreement between HFM and the client.
Fidelity Charitable Gift Fund. For those clients that desire to make a charitable contribution in excess of
$250,000, HFM has entered into an arrangement with Fidelity Investments Charitable Gift Fund (“Fidelity
Charitable”). Fidelity Charitable is a charitable trust organized under the laws of the Commonwealth of
Massachusetts, and is a charitable and is a charitable organization described in Section 501(c)(3) and
Section 509(a)(1) of the Internal Revenue Code. Fidelity Charitable operates donor-advised funds
described in Internal Revenue Code.
An HFM client can establish a Giving Account®, whereby the client, as the donor (the “Account Holder”)
makes an irrevocable charitable contribution(s) of personal assets (the “Assets”) to Fidelity Charitable.
Therefore, once the Assets are contributed by the Account Holder to the Giving Account, Fidelity
Charitable becomes the legal owner of the Assets. The Assets are held by, and remain the property of, the
Trustees of Fidelity Charitable, who have exclusive ownership and legal control over assets in the Giving
Account. Although the client (Account Holder) retains advisory privileges as to donation amounts to the
client’s desired charity recipients, the Trustees maintain ultimate legal authority and discretion over
investment and distribution decisions for the Giving Account.
Upon establishment of the Giving Account, and the corresponding nomination of the Account Holder,
Fidelity Charitable shall then engage HFM as the investment adviser for the Giving Account under its
Charitable Investment Advisor Program (the “Program”). HFM’s investment advisory fee is paid by Fidelity
Charitable. Fidelity Charitable will assess an annual administrative fee on the Assets, as more fully
described in the Program Description. Unless otherwise agreed upon by Fidelity Charitable, the Assets will
be custodied at National Financial Services LLC (“NFS”), a Fidelity affiliated entity.
Please Note: No client is under any obligation to establish a Giving Account. The client remains free to
make charitable contributions independent of the Giving account. If the client was to make a contribution
independent of the Giving Account, HFM would not earn an advisory fee on such amounts. Therefore, the
recommendation that the client establish a Giving Account creates the potential for a conflict of interest
since HFM has an incentive for the client to establish the Giving Account rather than make a charitable
contribution independent of the Giving Account.
Cybersecurity Risk. The information technology systems and networks that HFM and its third-party
service providers use to provide services to HFM’s clients employ various controls, which are designed to
prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause
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significant interruptions in HFM’s operations and result in the unauthorized acquisition or use of clients’
confidential or non-public personal information. Clients and HFM are nonetheless subject to the risk of
cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial
losses, cost and reputational damage to respond to regulatory obligations, other costs associated with
corrective measures, and loss from damage or interruption to systems. Although HFM has established
processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always
be successful, especially considering that HFM does not directly control the cybersecurity measures and
policies employed by third-party service providers. Clients could incur similar adverse consequences
resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients
invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and
other financial market operators, or other financial institutions.
Client Obligations. In performing our services, HFM shall not be required to verify any information
received from the client or from the client’s other professionals and is expressly authorized to rely
thereon. Moreover, each client is advised that it remains their responsibility to promptly notify HFM if
there is ever any change in their financial situation or investment objectives for the purpose of reviewing,
evaluating or revising our previous recommendations and/or services.
Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should
not be assumed that future performance of any specific investment or investment strategy (including the
investments and/or investment strategies recommended or undertaken by HFM) will be profitable or
equal any specific performance level(s).
Item 5 Fee Schedule
Portfolio Management Services
Our fee for portfolio management services is based on a percentage of the assets in your account and is
set forth in the following annual blended tiered fee schedule:
Assets Under Management Annual Fee
From
To
Annual %
First
$0
-
$100,000
1.25%
Next
$100,001 -
$250,000
1.10%
Next
$250,001 -
$500,000
0.90%
Next
$500,001 -
$1,000,000
0.70%
Next
$1,000,001
-
Over
0.50%
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As indicated below at Item 6, HFM, in its discretion, may charge a lesser or higher investment advisory
fee, charge a flat fee, waive its fee entirely, accept a lower relationship minimum, or charge fee on a
different interval based upon certain criteria (i.e. anticipated future earning capacity, anticipated future
additional assets, dollar amount of assets to be managed, related accounts, account composition,
complexity of the engagement, anticipated services to be rendered, grandfathered fee schedules,
employees and family members, courtesy accounts, competition, negotiations with client, etc.). Please
Note: As result of the above, similarly situated clients could pay different fees. In addition, similar advisory
services may be available from other investment advisers for similar or lower fees.
Our annual portfolio management fee is billed and payable quarterly in advance based on the value of
your account on the last business day of the preceding calendar quarter. If the portfolio management
agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a
pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the
quarter for which you are a client. Our advisory fee is negotiable depending on individual client
circumstances.
We will combine the account values of family members living in the same household to determine the
applicable advisory fee (unless instructed otherwise by the client). For example, we may combine account
values for you and your minor children, joint accounts with your spouse, and other types of related
accounts. Combining account values may increase the asset total, which may result in your paying a
reduced advisory fee based on the available breakpoints in our tiered fee schedule stated above.
Unless we agree to invoice you directly for our portfolio management services, we will deduct our fee
directly from your account through the qualified custodian holding your funds and securities. We will
deduct our advisory fee only when you have given our firm written authorization permitting the fees to
be paid directly from your account. Further, the qualified custodian will deliver an account statement to
you at least quarterly. These account statements will show all disbursements from your account, and you
should review all statements for accuracy. In the event we agree to invoice you directly, payment is due
within 30 days from the date of the invoice. Where invoices are not paid in full within the 30-day time
frame, we reserve the right to debit our fee from your account.
You may terminate the portfolio management agreement upon written notice to our firm in accordance
with the terms of the agreement for services. You will incur a pro rata charge for services rendered prior
to the termination of the portfolio management agreement, which means you will incur advisory fees only
in proportion to the number of days in the month for which you are a client.
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in
mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded
funds (described in each fund's prospectus) to their shareholders. These fees will generally include a
management fee and other fund expenses. You will also incur transaction charges and/or brokerage fees
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when purchasing or selling securities. These charges and fees are typically imposed by the broker-dealer
or custodian through whom your account transactions are executed. We do not share in any portion of
the brokerage fees/transaction charges imposed by the broker-dealer or custodian. To fully understand
the total cost you will incur, you should review all the fees charged by mutual funds, exchange traded
funds, our firm, and others. For information on our brokerage practices, refer to the
Brokerage Practices section (Item 12) of this disclosure brochure.
Compensation for the Sale of Securities or Other Investment Products
Our firm's Investment Advisor Representatives (IARs) are registered representatives with Osaic Wealth,
Inc. (“Osaic”), an unaffiliated securities broker-dealer, and a member of the Financial Industry Regualtory
Authority and the Securities Investor Protection Corporation. Additionally, certain IARs of our firm are also
be licensed as independent insurance agents and will earn commission-based compensation for selling
insurance products to you.
Additionally, members of H Financial Management could be invited to due diligence meetings at the
request of investment companies or other industry organizations. On occasion, travel reimbursements
are made by those companies that extended the invitation. Also, from time to time, HFM may receive
reimbursement for some expenses incurred in hosting client and/or marketing events. While these
payments may only reimburse travel or entertainment expenses, the appearance of “pay for production”
may exist and as such the potential conflict of interest exists.
In order to be clear, accounts that are held at Fidelity Institutional Wealth Services do not allow for any
commission payments of any kind to be paid to H Financial Management or any of its direct members.
HFM’s investment management fees, as described above, are shown on the Fidelity investment
statements.
ANY QUESTIONS: HFM’s Chief Compliance Officer, Kent D. Aloia, CFP®, AIF®, remains available to
address any questions regarding this Part 2A.
See additional important disclosure regarding advisory fees at Item 7 below.
Item 6 – Performance-Based Fees and Side-by-Side Management
H Financial Management does not charge any performance-based fees (fees based on a share of capital
gains on or capital appreciation of the assets of a client).
Item 7 – Types of Client
HFM’s clients are primarily individuals and families, with a limited number of retirement plan and business
clients. HFM generally recommends an aggregate relationship minimum of $750,000 to commence an
investment management engagement. HFM, in its discretion, may charge a lesser or higher investment
advisory fee, charge a flat fee, waive its fee entirely, accept a lower relationship minimum, or charge fee
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on a different interval, based upon certain criteria (i.e. anticipated future earning capacity, anticipated
future additional assets, dollar amount of assets to be managed, related accounts, account composition,
complexity of the engagement, anticipated services to be rendered, grandfathered fee schedules,
employees and family members, courtesy accounts, competition, negotiations with client, etc.). Please
Note: As result of the above, similarly situated clients could pay different fees. In addition, similar advisory
services may be available from other investment advisers for similar or lower fees.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
If an Adviser is engaged to provide Investment advice, the client’s current financial situation, needs, goals,
objectives, and risk tolerance are first evaluated. Once completed and the results are determined, the
advisor may offer clients investment advice which generally follows the principals of asset allocation. This
advice attempts to optimize the risk/reward profile of a client's portfolio by investing among several asset
classes based upon a client's personal financial goals and risk preferences. Below is a brief description of
the type of general strategies that may be used as guidelines by investment adviser representatives in
structuring accounts with varying objectives.
Conservative Income allocation. A conservative income portfolio usually seeks to generate income as its
primary objective and preserve initial investments as its secondary objective. Conservative income
portfolios tend to invest in a mix of income producing investments with a low degree of volatility. A typical
conservative income portfolio may consist of 0 - 30% in equity asset classes, and 70 - 100% in income asset
classes, including fixed income and/or cash equivalents.
Moderate Allocation. A moderate income portfolio usually seeks to generate income as its primary
objective with enough growth to keep pace with inflation. Moderate income portfolios tend to invest in
a predominantly income producing investments with a low degree of volatility and a smaller portion of
equities to encourage growth. A typical moderate income portfolio may consist of 30 - 50% in equity asset
classes, and 50 - 70% in income asset classes, including fixed income and/or cash equivalents.
Balanced Allocation. A balanced portfolio usually has both capital preservation and growth as its primary
objectives. Balanced portfolios tend to invest in a relatively equal mix of low to moderate risk securities. A
typical balanced portfolio may consist of 50 - 70% in equity asset classes and 30 - 50% in fixed income
and/or cash/cash equivalents.
Growth Allocation. A growth portfolio usually seeks to generate long-term capital gains as its primary
objective. Growth portfolios tend to invest in a mix of investments with potential for long-term capital
appreciation with a more than moderate amount of volatility. A typical growth allocation consists of 70 -
85% equity and 15 - 30% in fixed income and/or cash/cash equivalents.
Equity Growth Allocation. An equity growth portfolio usually seeks to generate long-term capital gains
as its primary objective. All Equity portfolios are aggressive portfolios and tend to invest in assets that
may be considered high risk and tend to have more volatility. These portfolios may have the potential for
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higher returns over the long-term. A typical all-equity portfolio consists of 85 - 100% equity and 0 - 15%
in fixed income and/or cash/cash equivalents.
Please Note: Deviations may occur relative to Account allocations during any specific short-term period
(6 months or less) due to market conditions or Adviser perceived and/or anticipated market
developments. Of course, there can be no assurance that any such perceived and/or anticipated market
developments will occur, be correct or prove profitable.
Since client portfolios are designed to be managed in accordance with the financial circumstances,
investment objectives, and preferences of individual clients, the actual asset allocation of a particular
account may differ from other client accounts with similar objectives or levels of risk. Asset allocation is
driven by various mathematical computations and is more complex than the concept of asset
diversification. It should be recommended that no strategy or allocation formula can guarantee a gain or
assume that an account will not suffer a loss.
The program is designed to offer clients a diversified long-term approach to their personal investment
goals and objectives. It is important that you keep your investment adviser representative informed as to
any changes in your financial situation. This service provides clients with individualized investment
portfolio management services, including account review, consolidated reporting, and investment
recommendation. Selected investments may include stocks, bonds, mutual funds and other securities.
HFM uses no-load, low expense mutual fund groups such as American Funds, T. Rowe Price, Vanguard,
and others. In addition, HFM uses low-cost exchange traded funds (ETFs) for passive investing and to
represent certain asset classes. These allocations are reviewed periodically by the HFM Investment
Committee which uses portfolio construction/reviews and other tools provided by American Funds,
Goldman Sachs, Fidelity, and JP Morgan among others. Also, we have investment management solutions
using individual stock and bond portfolios.
Additionally, there are complexities and risks associated with trading securities including, but not limited
to execution or trading errors, price volatility, bid/ask spreads, order types (such as “market” and “limit”
orders), deviation from net asset value and “execution price slippage” caused by lack of order or book
depth. This is commonly seen in some of the more thinly traded stocks or ETFs that don’t usually
experience a lot of daily trading volume. At current, H Financial Management heavily focuses on mutual
funds that trade once per day, this helps minimize problems associated with industry intra-day price
deficiencies. Exchange-traded funds (ETFs) are another tool that can be used by HFM to manage client
accounts, but the price execution risk is much higher with ETFs than mutual funds, because their price
fluctuates like a stock and can be traded multiple times per day.
Options Strategies.
In limited situations, upon client direction, HFM may engage in options transactions (or engage an
independent investment manager to do so) for the purpose of hedging risk and/or generating portfolio
income. The use of options transactions as an investment strategy can involve a high level of inherent risk.
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Option transactions establish a contract between two parties concerning the buying or selling of an asset
at a predetermined price during a specific period of time. During the term of the option contract, the
buyer of the option gains the right to demand fulfillment by the seller. Fulfillment may take the form of
either selling or purchasing a security, depending upon the nature of the option contract. Generally, the
purchase or sale of an option contract shall be with the intent of “hedging” a potential market risk in a
client’s portfolio and/or generating income for a client’s portfolio. Please Note: Certain options-related
strategies (i.e. straddles, short positions, etc.), may, in and of themselves, produce principal volatility
and/or risk. Thus, a client must be willing to accept these enhanced volatility and principal risks associated
with such strategies. In light of these enhanced risks, client may direct HFM, in writing, not to employ any
or all such strategies for his/her/their/its accounts.
Covered Call Writing.
Covered call writing is the sale of in-, at-, or out-of-the-money call options against a long security
position held in a client portfolio. This type of transaction is intended to generate income. It also
serves to create partial downside protection in the event the security position declines in value.
Income is received from the proceeds of the option sale. Such income may be reduced or lost to
the extent it is determined to buy back the option position before its expiration. There can be no
assurance that the security will not be called away by the option buyer, which will result in the
client (option writer) to lose ownership in the security and incur potential unintended tax
consequences. Covered call strategies are generally better suited for positions with lower price
volatility.
Long Put Option Purchases.
Long put option purchases allow the option holder to sell or “put” the underlying security at the
contract strike price at a future date. If the price of the underlying security declines in value, the
value of the long put option can increase in value depending upon the strike price and expiration.
Long puts are often used to hedge a long stock position to protect against downside risk. The
security/portfolio could still experience losses depending on the quantity of the puts bought,
strike price and expiration. In the event that the security is put to the option holder, it will result
in the client (option seller) to lose ownership in the security and to incur potential unintended tax
consequences. Options are wasting assets and expire (usually within months of issuance).
Please Note: There can be no guarantee that an options strategy will achieve its objective or prove
successful. No client is under any obligation to enter into any option transactions. However, if the client
does so, he/she must be prepared to accept the potential for unintended or undesired consequences (i.e.,
losing ownership of the security, incurring capital gains taxes). ANY QUESTIONS: HFM’s Chief Compliance
Officer, Kent Aloia, remains available to address any questions that a client or prospective client may
have regarding options.
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Item 9 – Disciplinary Information
Registered Investment Advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to one’s evaluation of H Financial Management or the integrity
of HFM’s management (and each supervised person providing investment advice). H Financial
Management has no information applicable to this item regarding the firm, the firm’s staff, or the firm’s
investment advisory representatives.
Item 10 – Other Financial Industry Activities and Affiliations
As indicated above at Item 4, HFM representatives serve as representatives of Osaic Wealth, Inc. member
FINRA/SIPC, and as licensed insurance agents. The recommendation by HFM that a client purchase a
securities or insurance-commission product from HFM’s representatives in their separate individual
capacities as representatives of Osaic and/or as insurance agents, presents a conflict of interest, as the
receipt of commissions may provide an incentive to recommend investment products based on
commissions to be received, rather than on a particular client’s need. No client is under any obligation to
purchase any securities or insurance commission products from HFM’s representatives. Clients are
reminded that they may purchase securities and insurance products recommended by HFM through
other, non-affiliated broker-dealers and/or insurance agencies.
HFM’s Chief Compliance Officer, Kent D. Aloia, CFP® AIF®, remains available to address any questions
that a client or prospective client may have regarding the above conflicts of interest.
Item 11 – Code of Ethics
H Financial Management has created a code of ethics that is designed to help educate and monitor the
business conduct of our office staff. The code emphasizes the firm’s fiduciary duty to clients and produces
a heavy burden on the staff to maintain client confidentiality.
Garrett S. Hoge, Kent D. Aloia, Jeffrey Karns or other employees of H Financial Management may
occasionally buy or sell securities for their own accounts. The firm may or may not recommend these
securities to clients since recommendations vary according to an individual client’s specific needs and
circumstances. Additionally, staff members may use automatic rebalancing programs that will actively
reallocate and may buy or sell securities without consideration of client holdings. These securities are
publicly traded, and it is highly unlikely that transactions in the personal accounts of the firm’s employees
could adversely affect the price or performance of the securities.
Should an employee become aware of any non-public information regarding a security, it is the firm’s
policy that the employees not act on such information for his/her own benefit or for the benefit of clients
and report the information to H Financial Management (and the proper regulatory authorities, if
warranted).
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Item 12 – Brokerage Practices
In the event that the client requests that HFM recommend a broker-dealer/custodian for execution and/or
custodial services, HFM generally recommends that investment HFM accounts be maintained at Fidelity.
Prior to engaging HFM to provide investment management services, the client will be required to enter
into a formal Investment Advisory Agreement with HFM setting forth the terms and conditions under
which HFM shall advise on the client's assets, and a separate custodial/clearing agreement with each
designated broker-dealer/custodian.
Factors that HFM considers in recommending Fidelity (or any other broker-dealer/custodian to clients)
include historical relationship with HFM, financial strength, reputation, execution capabilities, pricing,
research, and service. H Financial Management has an established history with Fidelity and feels that the
company characterizes industry leadership in its practices.
Non-Soft Dollar Research and Benefits: Although not a material consideration when determining whether
to recommend that a client utilize the services of a particular broker-dealer/custodian, HFM can receive
from Fidelity (or another broker-dealer/custodian, investment manager, platform or fund sponsor, or
vendor) without cost (and/or at a discount) support services and/or products, certain of which assist HFM
to better monitor and service client accounts maintained at such institutions. Included within the support
services that may be obtained by HFM may be investment-related research, pricing information and
market data, software and other technology that provide access to client account data, compliance and/or
practice management-related publications, discounted or gratis consulting services, discounted and/or
gratis attendance at conferences, meetings, and other educational and/or social events, marketing
support-including client events, computer hardware and/or software and/or other products used by HFM
in furtherance of its investment advisory business operations.
As indicated above, certain of the support services and/or products that may be received may assist HFM
in managing and administering client accounts. Others do not directly provide such assistance, but rather
assist HFM to manage and further develop its business enterprise.
There is no corresponding commitment made by HFM to Fidelity or any other any entity to invest any
specific amount or percentage of client assets in any specific mutual funds, securities or other investment
products as result of the above arrangement.
HFM’s Chief Compliance Officer, Kent D. Aloia, CFP®, AIF®, remains available to address any questions
that a client or prospective client may have regarding the above arrangements and the corresponding
conflict of interest presented by such arrangements.
Directed Brokerage. HFM recommends that its clients utilize the brokerage and custodial services
provided by Fidelity. HFM generally does not accept directed brokerage arrangements (when a client
requires that account transactions be affected through a specific broker-dealer). In such client directed
arrangements, the client will negotiate terms and arrangements for their account with that broker-dealer,
and HFM will not seek better execution services or prices from other broker-dealers or be able to "batch"
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the client’s transactions for execution through other broker-dealers with orders for other accounts
managed by HFM. As a result, a client may pay higher commissions or other transaction costs or greater
spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the
case. Please Note: In the event that the client directs HFM to effect securities transactions for the client’s
accounts through a specific broker-dealer, the client correspondingly acknowledges that such direction
may cause the accounts to incur higher commissions or transaction costs than the accounts would
otherwise incur had the client determined to effect account transactions through alternative clearing
arrangements that may be available through HFM. Higher transaction costs adversely impact account
performance. Please Also Note: Transactions for directed accounts will generally be executed following
the execution of portfolio transactions for non-directed accounts.
Order Aggregation. Transactions for each client account generally will be affected independently, unless
HFM decides to purchase or sell the same securities for several clients at approximately the same time.
HFM may (but is not obligated to) combine or “bunch” such orders to obtain best execution, to negotiate
more favorable commission rates or to allocate equitably among HFM’s clients differences in prices and
commissions or other transaction costs that might have been obtained had such orders been placed
independently. Under this procedure, transactions will be averaged as to price and will be allocated
among clients in proportion to the purchase and sale orders placed for each client account on any given
day. HFM shall not receive any additional compensation or remuneration as a result of such aggregation.
Item 13 – Review of Accounts
For those clients to whom HFM provides investment supervisory services, account reviews are conducted
on an ongoing basis by the HFM investment professional. All investment supervisory clients are advised
that it remains their responsibility to advise HFM of any changes in their investment objectives and/or
financial situation. All clients (in person or via telephone) are encouraged to review financial planning
issues (to the extent applicable), investment objectives and account performance with HFM on an annual
basis. HFM may conduct account reviews on an other than periodic basis upon the occurrence of a
triggering event, such as a change in client investment objectives and/or financial situation, market
corrections and client request.
Clients are provided with written transaction confirmation notices, and a written summary account
statement directly from the broker-dealer/custodian, at least quarterly. HFM may also provide a written
periodic report summarizing account activity and performance.
Item 14 – Client Referrals and Other Compensation
As indicated at Item 12 above, HFM can receive from Fidelity without cost (and/or at a discount), support
services and/or products. HFM’s clients do not pay more for investment transactions effected and/or
assets maintained at Fidelity as a result of this arrangement. There is no corresponding commitment made
by HFM to Fidelity or any other entity to invest any specific amount or percentage of client assets in any
specific mutual funds, securities, or other investment products as a result of the above arrangements.
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HFM’s Chief Compliance Officer, Kent D. Aloia, CFP®, AIF®, remains available to address any questions
that a client or prospective client may have regarding the above arrangements and the corresponding
conflict of interest presented by such arrangements.
HFM does not compensate individuals or entities for prospective client introductions.
Item 15 – Custody
HFM shall have the ability to deduct its advisory fee from the client’s Fidelity account on a quarterly basis.
Clients are provided with written transaction confirmation notices, and a written summary account
statement directly from Fidelity, at least quarterly.
Please Note: To the extent that HFM provides clients with periodic account statements or reports, the
client is urged to compare any statement or report provided by HFM with the account statements received
from the account custodian. Please Also Note: The account custodian does not verify the accuracy of
HFM’s advisory fee calculation.
In addition, certain clients may establish asset transfer authorizations that permit the qualified custodian
to rely upon instructions from HFM to transfer client funds or securities to third parties. To the extent
applicable, these arrangements will be disclosed at Item 9 of Part 1 of Form ADV. However, in accordance
with the guidance provided in the SEC’s February 21, 2017 Investment Adviser Association No-Action
Letter, the affected accounts are not subject to an annual surprise CPA examination. ANY QUESTIONS:
HFM’s Chief Compliance Officer, Kent D. Aloia, CFP®, AIF®, remains available to address any questions
that a client or prospective client may have regarding custody-related issues.
Item 16 – Investment Discretion
The client can determine to engage HFM to provide investment advisory services on a discretionary basis.
Prior to HFM assuming discretionary authority over a client’s account, the client shall be required to
execute an Investment Advisory Agreement, naming HFM as the client’s attorney and agent in fact,
granting HFM full authority to buy, sell, or otherwise effect investment transactions involving the assets
in the client’s name found in the discretionary account.
Clients who engage HFM on a discretionary basis may, at any time, impose restrictions, in writing, on
HFM’s discretionary authority (i.e. limit the types/amounts of particular securities purchased for their
account, exclude the ability to purchase securities with an inverse relationship to the market, limit or
proscribe HFM’s use of margin, etc.).
Item 17 – Voting Client Securities
H Financial Management does not vote proxies on behalf of clients. The proxies are sent from the
custodian or Investment Company directly to the client’s address of record. The client is welcome to vote
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proxies as they see fit. H Financial Management does not make recommendations as to how or for whom
to vote.
Item 18 – Financial Information
Registered Investment Advisors are required in this item to provide you with certain financial information
or disclosures about HFM’s financial condition. H Financial Management has no financial commitment
that impairs its ability to meet its financial obligations and fiduciary commitments to clients and has not
been the subject of a bankruptcy proceeding.
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PRIVACY NOTICE
H Financial Management (“HFM”) maintains physical, electronic, and procedural safeguards that
comply with federal standards to protect its clients’ nonpublic personal information (“information”).
Through this policy and its underlying procedures, HFM attempts to secure the confidentiality of customer
records and information and protect against anticipated threats or hazards to the security or integrity of
customer records and information.
It is the policy of HFM to restrict access to and/or the sharing of all current and former clients’
information (i.e., information and records pertaining to personal background [including social security
number and address],
investment objectives, financial situation, financial planning
issues, tax
information/returns, investment holdings, account numbers, account balances, etc.) to those employees
and affiliated/nonaffiliated entities who need to know that information in furtherance of the client’s
engagement of HFM.
HFM shall disclose, as necessary, the client’s information: (1) to unaffiliated service providers and
vendors in furtherance of establishing, maintaining, and reporting on the client’s HFM relationship (i.e.,
broker-dealer, account custodian, record keeper, technology, performance reporting, customer
relationship management software [CRM], proxy voting, insurance, independent managers, sub-advisers,
etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in
accordance with applicable federal and/or state privacy regulations.
However, HFM does not, and shall not, disclose or share information with any affiliated or
nonaffiliated persons, entities or service providers for marketing or any other purposes or reasons not
referenced above.
ANY QUESTIONS OR CONCERNS: Should you have any questions regarding the above,
please contact Kent D. Aloia, Chief Compliance Officer.
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