HAHN FINANCIAL GROUP, INC.

D I S C L O S U R E B R O C H U R E Office Address: Hahn Financial Building st 1000 E 41 St. Sioux Falls, SD 57105 Tel: 605-275-3600 Fax: 605-275-9595 office@hahnfinancialgroup.com www.HahnFinancialGroup.com O C T O B E R 1 6 , 2 0 2 5 This brochure provides information about the qualifications and business practices of Hahn Financial Group, Inc. Being registered as a registered investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 605-275-3600. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about Hahn Financial Group, Inc. (CRD #169787) is available on the SEC’s website at www.adviserinfo.sec.gov i Hahn Financial Group, Inc.  Item 2: Material Changes Annual Update Material Changes since the Last Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. • Since the last filing of this brochure on February 16, 2025 the following has been updated: Item 4 has been updated to disclose the firm’s ownership has changed to an ESOP and to disclose the most recent calculation for client assets under Full Brochure Available management. This Firm Brochure being delivered is the complete brochure for the Firm. ii Hahn Financial Group, Inc.  Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 1: Cover Page Item 2: Material Changes .................................................................................................................... ii Annual Update ................................................................................................................................................. ii Material Changes since the Last Update ............................................................................................... ii Item 3: Table of Contents ................................................................................................................... iii Full Brochure Available ............................................................................................................................... ii Item 4: Advisory Business .................................................................................................................. 1 Firm Description ............................................................................................................................................ 1 Client Tailored Services and Client Imposed Restrictions ............................................................. 1 Wrap Fee Programs ...................................................................................................................................... 1 Types of Advisory Services ........................................................................................................................ 1 Item 5: Fees and Compensation ....................................................................................................... 5 Client Assets under Management ............................................................................................................ 5 Method of Compensation and Fee Schedule........................................................................................ 5 Client Payment of Fees ................................................................................................................................. 8 Additional Client Fees Charged ................................................................................................................ 8 Prepayment of Client Fees .......................................................................................................................... 9 Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 9 External Compensation for the Sale of Securities to Clients ......................................................... 9 Item 7: Types of Clients ....................................................................................................................... 9 Sharing of Capital Gains ............................................................................................................................... 9 Description ....................................................................................................................................................... 9 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 9 Account Minimums ....................................................................................................................................... 9 Methods of Analysis ...................................................................................................................................... 9 Charting analysis ............................................................................................................................................ 9 Fundamental analysis .................................................................................................................................. 9 Technical analysis .......................................................................................................................................... 9 iii Hahn Financial Group, Inc.  Cyclical analysis .............................................................................................................................................. 9 Investment Strategy ....................................................................................................................................10 Item 9: Disciplinary Information ................................................................................................... 11 Security Specific Material Risks .............................................................................................................10 Criminal or Civil Actions ...........................................................................................................................11 Administrative Enforcement Proceedings .........................................................................................11 Item 10: Other Financial Industry Activities and Affiliations ............................................. 11 Self-Regulatory Organization Enforcement Proceedings .............................................................11 Broker-Dealer or Representative Registration ................................................................................11 Futures or Commodity Registration .....................................................................................................11 Material Relationships Maintained by this Advisory Business and Conflicts of Interest 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Recommendations or Selections of Other Investment Advisors and Conflicts of Interest11 Trading ................................................................................................................................................... 12 Code of Ethics Description .......................................................................................................................12 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest .............................................................................................................................................................12 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest .............................................................................................................................................................13 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Item 12: Brokerage Practices ......................................................................................................... 13 Transactions and Conflicts of Interest .................................................................................................13 Factors Used to Select Broker-Dealers for Client Transactions .................................................13 Item 13: Review of Accounts ........................................................................................................... 14 Aggregating Securities Transactions for Client Accounts ............................................................14 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ..........................................................................................................................................14 Review of Client Accounts on Non-Periodic Basis ..........................................................................14 Item 14: Client Referrals and Other Compensation ................................................................ 15 Content of Client Provided Reports and Frequency .......................................................................14 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ........................................................................................................................................................15 Advisory Firm Payments for Client Referrals ...................................................................................15 iv Hahn Financial Group, Inc.  Item 15: Custody .................................................................................................................................. 15 Item 16: Investment Discretion ..................................................................................................... 16 Account Statements ....................................................................................................................................15 Item 17: Voting Client Securities ................................................................................................... 16 Discretionary Authority for Trading ....................................................................................................16 Item 18: Financial Information ...................................................................................................... 16 Proxy Votes ....................................................................................................................................................16 Balance Sheet .................................................................................................................................................16 Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................16 Brochure Supplement (Part 2B of Form ADV) .......................................................................... 18 Bankruptcy Petitions during the Past Ten Years .............................................................................16 Principal Executive Officer .......................................................................................................................18 ® Kelly Ann Hahn, ChFC ..............................................................................................................................18 Educational Background and Business Experience .......................................................................18 Other Business Activities Engaged In ..................................................................................................19 Additional Compensation .........................................................................................................................19 Disciplinary Actions ....................................................................................................................................19 Brochure Supplement (Part 2B of Form ADV) .......................................................................... 21 Supervision .....................................................................................................................................................19 Principal Executive Officer .......................................................................................................................21 ® ® ® ChFC CLU ...................................................................................................21 Verlyn Earl Hahn, CFP Educational Background and Business Experience .......................................................................21 Other Business Activities Engaged In ..................................................................................................22 Additional Compensation .........................................................................................................................22 Disciplinary Actions ....................................................................................................................................23 Supervision .....................................................................................................................................................23 v Hahn Financial Group, Inc.  Item 4: Advisory Business Firm Description Hahn Financial Group, Inc., (“HFG”) was founded in 2006 and became a registered investment advisor in 2014. Hahn Financial Group Inc. ESOP Trust is 100% owner. Kelly Hahn is Chief Compliance Officer and Verlyn Hahn is President. HFG provides investment management to individuals, pension and profit sharing plans, trusts, estates, and charitable organizations. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, insurance review, investment management, education funding, retirement planning, and estate planning. HFG is a fee based investment management firm. The firm also sells insurance products for a commission. HFG does not act as a custodian of client assets. An evaluation of each client's initial situation is assessed via a net worth statement or risk analysis. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Client Tailored Services and Client Imposed Restrictions Other professionals (e.g., lawyers, accountants, tax preparers, insurance agents, etc.) are engaged directly by the client on an as-needed basis and may charge fees of their own. For example, tax preparation and to the extent your estate plan needs to be updated, the tax preparer and/or attorney will bill the client separately. Conflicts of interest will be disclosed to the client in the event they should occur. The goals and objectives for each client are documented in our client files. Investment strategies are created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Wrap Fee Programs Agreements may not be assigned without written client consent. Types of Advisory Services HFG does not sponsor any wrap fee programs. ASSET MANAGEMENT HFG offers discretionary direct asset management services to advisory clients. HFG will offer clients ongoing portfolio management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The client will authorize HFG discretionary authority to execute selected investment program transactions as stated within the Endowments Investment Advisory Agreement. HFG offers discretionary direct asset management services to endowment clients as follows: - 1 - Hahn Financial Group, Inc.  • • • facilitate an annual review with • Endowment/Investment Committee Education: Educational presentations for the committee will be informational in nature and intended to provide an overview of the IPS and the Endowment’s investment selections that would align with their IPS. Develop Investment Policy Statement (IPS): The Committee’s goals and objectives will be obtained to help determine the appropriate IPS and investment selections. Annual Review: Advisor will the Endowment/Investment Committee covering the IPS/Investments to ensure alignment with the Committee’s current goals and objectives. Quarterly Reports: quarterly paper statements will be provided to the contact person for the Endowment Committee. SELECTION OF OTHER ADVISORS When deemed appropriate for the client, HFG will select other advisors for the management of some or all of a client’s account. These other advisors may charge fees in addition to the fees charged by HFG or may be paid a portion of the fee charged by HFG. Wealth Management, LLC The details on fees will be disclosed in Item 5 of this brochure. HFG when deemed appropriate for the client will utilize Wealth Management, LLC (“Sub- Advisor”) to perform discretionary investment management services for certain clients using Sub-Advisor’s Asset Allocation Models. Sub-Advisor shall have discretionary authority for the investment and reinvestment of the designated assets with full authority to buy, sell or otherwise effect investment transactions involving the designated assets in the client’s name and for the client’s account. The authority granted to Sub-Advisor will continue in force until revoked by HFG or client in writing, with such revocation effective upon Sub-Advisor receipt. HFG is the primary investment advisor to the Clients and shall obtain from client’s information to determine Client’s financial situation and investment objectives and forward such information to Sub-Advisor in the form reasonably requested by Sub- Advisor prior to Sub-Advisor’s obligation to provide services to client. • QUALIFIED PLANS HFG will provide qualified plans with the following services: • Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Investment options, retention, removal, addition of investment options and all other investment review duties will be assigned to an unaffiliated asset manager. • Assist the Client in the reviewing and understanding of the investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan, provided by the asset manager. Client shall have the ultimate responsibility to ensure the asset manager continues to follow the IPS and provides the appropriate reports and investment reviews demonstrating that the policies and objectives outlined in the IPS are being followed. Educate the Plan Sponsor with respect to the asset manager’s selection of a qualified default investment alternative for participants who are automatically enrolled in the - 2 - Hahn Financial Group, Inc.  • Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants. • Assist the Plan Sponsor in monitoring investment options by reviewing the periodic asset manager’s investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS, along with the asset manager’s recommendations to maintain, remove or replace investment options. • Meet with Client on a periodic basis to discuss the reports and the investment recommendations provided by the asset manager. • Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. HFG will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan under this agreement. Any specific recommendations to participants will be under a separate agreement between the participant and HFG. • Assist in the participant enrollments as needed, in order to increase retirement plan participation among the employees and investment and financial understanding by the employees. Meet with the asset manager periodically to understand their policies, procedures, objectives, processing and assist the Plan Sponsor in understanding those policies, procedures, etc. HFG may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between HFG and Client. HFG has no responsibility to provide services related to the following types of assets (“Excluded Assets”): 1. 2. 3. 4. 5. 6. 7. Employer securities; Real estate (except for real estate funds or publicly traded REITs); Stock brokerage accounts or mutual fund windows; Participant loans; Non-publicly traded partnership interests; Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or not Other hard-to-value or illiquid securities or property. be included in the calculation of Fees paid to HFG under this Excluded Assets will Agreement. ERISA PLAN SERVICES HFG provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. Limited Scope ERISA 3(21) Fiduciary. HFG may act as a 3(21). HFG may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions on a non-discretionary basis. As an investment advisor HFG has a fiduciary duty to act in the - 3 - Hahn Financial Group, Inc.  • best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using HFG can help the plan sponsor mitigate liability by following a diligent process. Fiduciary Services are: • • • • Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Investment options, retention, removal, addition of investment options and all other investment review duties will be assigned to a 3(38) Fiduciary. Assist the Client in the reviewing and understanding of the investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan, provided by the 3(38) Fiduciary. Client shall have the ultimate responsibility to ensure the 3(38) Fiduciary continues to follow the IPS and provides the appropriate reports and investment reviews showing that the policies and objectives outlined in the IPS are being followed. Educate the Plan Sponsor with respect to the 3(38) Fiduciary’s selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5. Assist the Plan Sponsor in monitoring investment options by reviewing the periodic 3(38) Fiduciary’s investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS, along with the 3(38) Fiduciary’s recommendations to maintain, remove or replace investment options. Meet with Client on a periodic basis to discuss the reports and the investment recommendations provided by the 3(38) Fiduciary. • Non-fiduciary Services are: • • Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands HFG’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, HFG is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. Advisor will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan under this agreement. Any specific recommendations to participants will be under a separate agreement between the participant and HFG. Assist participant enrollments as needed, in order to increase retirement plan participation among the employees and investment and financial understanding by the employees. Meet with the 3(38) Fiduciary periodically to understand their policies, procedures, objectives, processing and assist the Plan Sponsor in understanding those policies, procedures, etc. - 4 - Hahn Financial Group, Inc.  HFG may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Advisor and Client. HFG has no responsibility to provide services related to the following types of assets (“Excluded Assets”): 1. 2. 3. 4. 5. 6. 7. Employer securities; Real estate (except for real estate funds or publicly traded REITs); Stock brokerage accounts or mutual fund windows; Participant loans; Non-publicly traded partnership interests; Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or not Other hard-to-value or illiquid securities or property. be included in the calculation of Fees paid to HFG on the ERISA Excluded Assets will Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. Client Assets Under Management NEWSLETTERS AND PERIODICALS HFG provides newsletters and periodicals to clients. There is no charge to the client for this service. HFG has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: $0 Date Calculated: September 29, 2025 $171,187,706 Item 5: Fees and Compensation Method of Compensation and Fee Schedule ASSET MANAGEMENT HFG offers discretionary direct asset management services to advisory clients. HFG charges an annual investment advisory fee based on the total assets under management as follows: The fees payable to HFG Assets Under Management $0 to $49,999 $50,000 to $199,999 $200,000 to $499,999 $500,000 to $999,999 $1,000,000 to $1,999,999 $2,000,000 to $2,999,999 $3,000,000 to $3,999,999 $4,000,000 to $4,999,999 $5,000,000 or more Annual Fee 1.75% 1.50% 1.25% 1.00% .90% .80% .70% .60% .50% The annual Fee may be negotiable based on the amount of assets, the investments to be utilized and the complexity of the account. Accounts within the same household may be - 5 - Hahn Financial Group, Inc.  combined for a reduced fee. Fees are billed quarterly in advance based on the amount of assets managed as of the last business day of the previous quarter. Initial fees for partial quarters are waived. Quarterly advisory fees are deducted from the clients' account by the custodian. Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement for a full refund. Clients may terminate advisory services with seven (7) days written notice. Upon Client termination, management fees will be pro-rated to the effective date of termination. Client will receive a refund of management fees paid but not yet earned through the effective date of termination except for management fees totaling less than or equal to $50 per Client. The $50 is considered as the administrative costs to process the termination. “The date of termination” is defined as the date of total withdrawal or total transfer from the account. If unearned management fees total more than $50 per Client upon termination, they will be refunded in total to the Client. (Pro rata is calculated by multiplying the Annual Fee by the Account Value divided by the number of days left in the quarter divided by 360 days. For example if the Account value was $500,000 and the account was closed with 15 days left in the quarter the calculation would be (1% x 500,000) x (15/360) = $208.33.) Client shall be given thirty (30) days prior written notice of any increase in fees, and client will acknowledge, in writing, any agreement of increase in said fees. ENDOWMENTS HFG charges an annual investment advisory fee based on the total assets under management as follows: The fees payable to HFG Assets Under Management $50,000 to $2,000,000 $2,000,001 to $5,000,000 $5,000,001 or more Annual Fee 0.50% 0.42% 0.35% The annual Fee may be negotiable based on the amount of assets, the investments to be utilized and the complexity of the account. Accounts within the same organization may be combined for a reduced fee. Fees are billed quarterly in advance based on the amount of assets managed as of the last business day of the previous quarter. Initial fees for partial quarters are waived. Quarterly advisory fees deducted from the clients' account by the custodian will be reflected in a provided fee invoice, as part of the quarterly statement, as fees are withdrawn. Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement for a full refund. Clients may terminate advisory services with seven (7) days written notice. Upon Client termination, management fees will be pro-rated to the effective date of termination. Participant will receive a refund of management fees paid but not yet earned through the effective date of termination except for management fees totaling less than or equal to $50 per Client. The $50 is considered as the administrative costs to process the termination. “The date of termination” is defined as the date of total withdrawal or total - 6 - Hahn Financial Group, Inc.  transfer from the account. If unearned management fees total more than $50 per Client upon termination, they will be refunded in total to the Client. (Pro rata is calculated by multiplying the Annual Fee by the Account Value divided by the number of days left in the quarter divided by 360 days. For example if the Account value was $200,000 and the account was closed with 15 days left in the quarter the calculation would be (.5% x 200,000) x (15/360) = $41.67.) Client shall be given thirty (30) days prior written notice of any increase in fees, and client will acknowledge, in writing, any agreement of increase in said fees. FEES ASSOCIATED WITH THE SELECTION OF OTHER ADVISORS Wealth Management, LLC The fees payable to the Adviser are as follow below. Wealth Management, LLC (“Sub-Advisor”) does not charge fees in addition to the fees charged by HFG, they will receive 20% of the fees charged by HFG detailed above in the fee schedule titled “The fees payable to HFG”. The client will pay no additional fees when this sub-manager is used. QUALIFIED PLANS The annual fee for services shall be calculated as follows: The fees payable to HFG Assets Under Management Annual Fee $0 to $9,999,999 .50% $10,000,000 to $99,999,999 .45% $100,000,000 to $149,999,999 .40% $150,000,000 to $199,999,999 .35% $200,000,000 to $249,999,999 .30% $250,000,000 or more .25% The annual fee is negotiable. Fees are charged, as noted above, based on the assets as calculated by the custodian or record keeper of the Included Assets (without adjustments for anticipated withdrawals by Plan participants or other anticipated or scheduled transfers or distribution of assets) on the last business day of the previous quarter. Initial fees for partial quarters are waived. If this Agreement is terminated prior to the end of the fee period, HFG shall be entitled to a prorated fee based on the number of days during the fee period services were provided or Client will be due a prorated refund of fees for days services were not provided in the fee period. The fee schedule, which includes compensation of HFG for the services, is described in detail in Schedule A of the Qualified Plan Agreement. The Plan is obligated to pay the fees, however the Plan Sponsor may elect to pay the fees. Client may elect to be billed directly or have fees deducted from Plan Assets. HFG does not reasonably expect to receive any additional compensation, directly or indirectly, for its services under this Agreement. If additional compensation is received, HFG will disclose this compensation, the services - 7 - Hahn Financial Group, Inc.  rendered, and the payer of compensation. HFG will offset the compensation against the fees agreed upon under this Agreement. ERISA PLAN SERVICES The annual fees are based on the market value of the Included Assets as follows: The fees payable to HFG Assets Under Management Annual Fee $0 to $9,999,999 .50% $10,000,000 to $99,999,999 .45% $100,000,000 to $149,999,999 .40% $150,000,000 to $199,999,999 .35% $200,000,000 to $249,999,999 .30% $250,000,000 or more .25% The annual fee is negotiable. Fees are charged, as noted above, based on the assets as calculated by the custodian or record keeper of the Included Assets (without adjustments for anticipated withdrawals by Plan participants or other anticipated or scheduled transfers or distribution of assets) on the last business day of the previous quarter. Initial fees for partial quarters are waived. If this Agreement is terminated prior to the end of the fee period, HFG shall be entitled to a prorated fee based on the number of days during the fee period services were provided or Client will be due a prorated refund of fees for days services were not provided in the fee period. Client Payment of Fees The fee schedule, which includes compensation of HFG for the services, is described in detail in Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees, however the Plan Sponsor may elect to pay the fees. Client may elect to be billed directly or have fees deducted from Plan Assets. HFG does not reasonably expect to receive any additional compensation, directly or indirectly, for its services under this Agreement. If additional compensation is received, HFG will disclose this compensation, the services rendered, and the payer of compensation. HFG will offset the compensation against the fees agreed upon under this Agreement. Additional Client Fees Charged Investment management fees are billed quarterly in advance, meaning we bill you before the three-month period has started. Payment in full is expected upon invoice presentation. Fees are usually deducted from a designated client account to facilitate billing. The client must consent in advance to direct debiting of their investment account. Custodians may charge transaction fees on purchases or sales of certain mutual funds, include Mutual Fund equities, and exchange-traded funds. These charges may transactions fees, postage and handling and miscellaneous fees (fee levied to recover costs associated with fees assessed by self-regulatory organizations). These transaction charges are usually small and incidental to the purchase or sale of a security. The - 8 - Hahn Financial Group, Inc.  selection of the security is more important than the nominal fee that the custodian charges to buy or sell the security. HFG does not receive any portion of these fees. Prepayment of Client Fees For more details on the brokerage practices, see Item 12 of this brochure. External Compensation for the Sale of Securities to Clients HFG does not require prepayment of fees of more than $500 per client and six months or more in advance. HFG does not receive any external compensation for the sale of securities to clients. Item 6: Performance-Based Fees and Side-by-Side Management Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. HFG does not use a performance-based fee structure because of the conflict of interest. Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client. Item 7: Types of Clients Description HFG generally provides investment advice to individuals, trusts, estates, charitable organizations, and pension plans. Account Minimums Client relationships vary in scope and length of service. HFG does not require a minimum to open an account but some money managers may require a minimum. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental, technical, and cyclical analysis. Investing in securities involves risk of loss that clients should be prepared to bear. Past performance is not a guarantee of future returns. Charting analysis involves the use of patterns in performance charts. HFG uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Technical analysis involves the analysis of past market data; primarily price and volume. Cyclical analysis involved the analysis of business cycles to find favorable conditions for buying and/or selling a security. - 9 - Hahn Financial Group, Inc.  Investment Strategy The main sources of information include financial newspapers and magazines, research materials prepared by others, corporate rating services, annual reports, prospectuses, and filings with the Securities and Exchange Commission. The investment strategy for a specific client is based upon the objectives stated by the client during consultations. The client may change these objectives at any time. Each client executes an Investment Policy Statement, Risk Tolerance or similar form that documents their objectives and their desired investment strategy. Security Specific Material Risks Other strategies may include long-term purchases, short-term purchases, trading, and option writing (including covered options, uncovered options or spreading strategies). All investment programs have certain risks that are borne by the investor. Fundamental analysis may involve interest rate risk, market risk, business risk, and financial risk. Risks involved in technical analysis are inflation risk, reinvestment risk, and market risk. Cyclical analysis involves inflation risk, market risk, and currency risk. Interest-rate Risk • Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks and should discuss these risks with HFG: • Market Risk : Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • : The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market Inflation Risk events. : When any type of inflation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of • Currency Risk inflation. • Reinvestment Risk : Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Business Risk : This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Liquidity Risk : These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. : Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized - 10 - Hahn Financial Group, Inc.  • Financial Risk product. For example, Treasury Bills are highly liquid, while real estate properties are not. : Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Item 9: Disciplinary Information Criminal or Civil Actions Administrative Enforcement Proceedings The firm and its management have not been involved in any criminal or civil action. Self-Regulatory Organization Enforcement Proceedings The firm and its management have not been involved in administrative enforcement proceedings. The firm and its management have not been involved in legal or disciplinary events related to past or present investment clients. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration Futures or Commodity Registration HFG is not registered as a broker dealer, and its employees are not registered representatives of an unaffiliated broker-dealer. Neither HFG nor its employees are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading Material Relationships Maintained by this Advisory Business and Conflicts of Interest advisor. Kelly Hahn and Verlyn Hahn are also licensed insurance agents through Hahn Financial Group, Inc. Approximately 5% of Kelly’s time and approximately 30% of Verlyn’s time is spent in this practice. From time to time, they will offer clients services from those activities. These practices represent conflicts of interest because they give an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures, and the firm’s Fiduciary obligation to place the best interest of the client first and the clients are not required to purchase any products. Clients have the option to purchase these products through another insurance agent of their choosing. Recommendations or Selections of Other Investment Advisors and Conflicts of Interest HFG may at times utilize the services of another investment advisor, Wealth Management, to manage client accounts. This situation may create a conflict of interest as the fees retained by HFG may be higher with some advisors. However, when referring clients to other investment advisors, the client’s best interest will be the main determining factor of - 11 - Hahn Financial Group, Inc.  These fees do not include brokerage fees that may be assessed by the custodial HFG. broker dealer. Fees for these services will be based on a percentage of assets under management not to exceed any limit imposed by any regulatory agency which are detailed in Item 5 of this brochure. This relationship will be disclosed to the client in each contract between HFG and the other investment advisor. Client will initial HFG's Investment Advisory Agreement to acknowledge receipt of Third Party fee Schedule and required documents including Form ADV Part 2 disclosures. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description The employees of HFG have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of HFG employees and addresses conflicts that may arise. The Code defines acceptable behavior for employees of HFG. The Code reflects HFG and its supervised persons’ responsibility to act in the best interest of their client. One area which the Code addresses is when employees buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our clients. We do not allow any employees to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our clients. HFG’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other employee, officer or director of HFG may recommend any transaction in a security or its derivative to advisory clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. HFG’s Code is based on the guiding principle that the interests of the client are our top priority. HFG’s officers, directors, advisors, and other employees have a fiduciary duty to our clients and must diligently perform that duty to maintain the complete trust and confidence of our clients. When a conflict arises, it is our obligation to put the client’s interests over the interests of either employees or the company. to clients, or who have access The Code applies to “access” persons. “Access” persons are employees who have access to non-public information regarding any clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to such recommendations that are non-public. The firm will provide a copy of the Code of Ethics to any client or prospective client upon Investment Recommendations Involving a Material Financial Interest and Conflict of request. Interest HFG and its employees do not recommend to clients securities in which we have a material financial interest. - 12 - Hahn Financial Group, Inc.  Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest HFG and its employees may buy or sell securities that are also held by clients. In order to mitigate conflicts of interest such as front running, employees are required to disclose all reportable securities transactions as well as provide HFG with copies of their brokerage statements. The Chief Compliance Officer of HFG is Kelly Hahn. She reviews all employee trades each quarter. The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the firm receive preferential treatment over employee transactions. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest HFG does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. However, employees may buy or sell securities at the same time they buy or sell securities for clients. In order to mitigate conflicts of interest such as front running, employees are required to disclose all reportable securities transactions as well as provide HFG with copies of their brokerage statements. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions HFG will recommend the use of a particular broker-dealer based on their duty to seek best execution for the client, meaning they have an obligation to obtain the most favorable terms for a client under the circumstances. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is affected, the ability to effect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. HFG will select appropriate brokers based on a number of factors including but not limited to their relatively low transaction fees and reporting ability. HFG relies on its broker to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by HFG. HFG does not receive any portion of the trading fees. • Directed Brokerage HFG will recommend the use of Charles Schwab & Co., Inc. • Best Execution In circumstances where a client directs HFG to use a certain broker-dealer, HFG still has a fiduciary duty to its clients. The following may apply with Directed Brokerage: HFG 's inability to negotiate commissions, to obtain volume discounts, there may be a disparity in commission charges among clients and conflicts of interest arising from brokerage firm referrals. Investment advisors who manage or supervise client portfolios on a discretionary basis have a fiduciary obligation of best execution. The determination of what may - 13 - Hahn Financial Group, Inc.  • Soft Dollar Arrangements constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is effected, the ability to effect the transaction where a large block is involved, the operational facilities of the broker- dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. The firm does not receive any portion of the trading fees. The Securities and Exchange Commission defines soft dollar practices as arrangements under which products or services other than execution services are obtained by HFG from or through a broker-dealer in exchange for directing client transactions to the broker-dealer. As permitted by Section 28(e) of the Securities Exchange Act of 1934, HFG receives economic benefits as a result of commissions generated from securities transactions by the broker-dealer from the accounts of HFG. These benefits include both proprietary research from the broker and other research written by third parties. Aggregating Securities Transactions for Client Accounts A conflict of interest exists when HFG receives soft dollars. This conflict is mitigated by disclosures, procedures, and the firm’s Fiduciary obligation to act in the best interest of its clients and the services received are beneficial to all clients. HFG is authorized in its discretion to aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of HFG. All clients participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rated basis. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Account reviews are performed quarterly by IARs of HFG. Account reviews are performed Review of Client Accounts on Non-Periodic Basis more frequently when market conditions dictate. Content of Client Provided Reports and Frequency Other conditions that may trigger a review of clients’ accounts are changes in the tax laws, new investment information, and changes in a client's own situation. Clients receive account statements no less than quarterly for managed accounts. Account statements are issued by the Asset Manager’s custodian. Clients are urged to review the account statements received directly from their custodians. Client receives confirmations of each transaction in their account from the custodian and an additional statement during any month in which a transaction occurs. - 14 - Hahn Financial Group, Inc.  Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Advisory Firm Payments for Client Referrals HFG receives additional economic benefits from external sources as described above in Item 12. HFG does not compensate for client referrals. Item 15: Custody Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to clients at their address of record at least quarterly. HFG is deemed to have constructive custody solely because advisory fees are directly deducted from client’s account by the custodian on behalf of HFG and due to its third- party money movement authority. HFG and its qualified custodian meet the following seven (7) conditions in order to avoid maintaining full custody: 1. The Client provides an instruction to the qualified custodian, in writing, that includes the Client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The Client authorizes HFG, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The Client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the Client’s authorization, and provides a transfer of funds notice to the Client promptly after each transfer. 4. The Client has the ability to terminate or change the instruction to the Client’s qualified custodian. 5. HFG has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the Client’s instruction. 6. HFG maintains records showing that the third party is not a related party of HFG or located at the same address as HFG. 7. The Client’s qualified custodian sends the Client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at their address of record at least quarterly. Clients are urged to compare the account statements received directly from their custodians to any documentation or reports prepared by HFG. - 15 - Hahn Financial Group, Inc.  Item 16: Investment Discretion Discretionary Authority for Trading HFG accepts discretionary authority to manage securities accounts on behalf of clients. HFG has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The client will authorize HFG discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. The client approves the custodian to be used and the commission rates paid to the custodian. HFG does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17: Voting Client Securities Proxy Votes HFG does not vote proxies on securities. Clients are expected to vote their own proxies. The client will receive their proxies directly from the custodian of their account or from a transfer agent. When assistance on voting proxies is requested, HFG will provide recommendations to the client. If a conflict of interest exists, it will be disclosed to the client. Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided because HFG does not serve as a custodian for client funds or securities and HFG does not require prepayment of fees of more than $500 per client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients Bankruptcy Petitions during the Past Ten Years HFG has no condition that is reasonably likely to impair our ability to meet contractual commitments to our clients. Neither HFG nor its management has had any bankruptcy petitions in the last ten years. - 16 - Hahn Financial Group, Inc.  S U P E R V I S E D P E R S O N B R O C H U R E F O R M A D V P A R T 2 B Kelly Ann Hahn, ChFC® Office Address: Hahn Financial Building st 1000 E 41 St. Sioux Falls, SD 57105 Tel: 605-275-3600 Fax: 605-275-9595 KellyHahn@HahnFinancialGroup.com O C T O B E R 1 6 , 2 0 2 5 This brochure supplement provides information about Kelly Ann Hahn and supplements the Hahn Financial Group, Inc.’s brochure. You should have received a copy of that brochure. Please contact Hahn Financial Group, Inc. if you did not receive the brochure or if you have any questions about the contents of this supplement. Additional information about Kelly Ann Hahn (CRD #4632939) is available on the SEC’s website at www.adviserinfo.sec.gov. - 17 - Hahn Financial Group, Inc.  Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Principal Executive Officer Kelly Ann Hahn, ChFC® • Educational Background and Business Experience Year of birth: 1960 • Educational Background: Iowa Methodist Medical Center Nursing School; RN Degree; 5/1981 Professional Certifications: Employees have earned certifications and credentials that are required to be explained in further detail. ® ® ® (ChFC ): Chartered Financial Consultant (ChFC ) is a ® • Chartered Financial Consultant designation issued by the American College. ChFC designation requirements: ® • Complete ChFC coursework within five years from the date of initial enrollment. • Pass the exams for all required elective courses. A minimum score of 70% must be achieved to pass. • Meet the experience requirements: Three years of full-time business experience within the five years preceding the date of the award. An undergraduate or graduate degree from an accredited educational institution qualifies as one year of business experience. • Take the Professional Ethics Pledge. ® designation, you must earn 30 hours of continuing When you achieve your ChFC education credit every two years. • Business Experience: • • • • • • • • • Hahn Financial Group, Inc.; CCO/Investment Advisor Representative; 01/2014- Present Hahn Financial Group, Inc.; Insurance Agent; 10/2006-Present Hahn Holding I, LLC; Managing Member; 11/2006-Present Hahn Holding II, LLC; Managing Member; 11/2006-Present Gradient Securities, LLC; Registered Representative; 1/2014-12/2014 American United Life; Agent; 11/2006-01/2014 OneAmerica Securities; Investment Advisor Representative; 11/2006-1/2014 OneAmerica Securities; Registered Representative; 11/2006-12/2013 Thrivent Investment Management Inc.; Investment Advisor Representative; 02/2003-10/2006 Thrivent Financial for Lutherans; Partner, Great Plains Region; 07/2002- 10/2006 - 18 - Hahn Financial Group, Inc.  Other Business Activities Engaged In Additional Compensation Kelly Hahn has a financial industry affiliated business as an insurance agent. Approximately 5% of her time is spent in this business. From time to time, she offers clients advice or products from those activities. Clients are not required to purchase any products. These practices represent conflicts of interest because they give an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures, and the firm’s Fiduciary obligation to place the interests of the client first and clients are not required to purchase any products. Clients have the option to purchase these products through another insurance agent of their choosing. Disciplinary Actions Mrs. Hahn receives no additional compensation other than her salary from Hahn Financial Group. She does not receive any performance-based fees. Supervision None to report. Kelly Hahn is the Chief Compliance Officer of Hahn Financial Group, Inc. She is responsible for formulation and monitoring of investment advice offered to clients and all supervision. She will adhere to the policies and procedures as described in the firm’s Compliance Manual. - 19 - Hahn Financial Group, Inc.  S U P E R V I S E D P E R S O N B R O C H U R E F O R M A D V P A R T 2 B Verlyn Earl Hahn CFP® ChFC®, CLU® Office Address: Hahn Financial Building st 1000 E. 41 St. Sioux Falls, SD 57105 Tel: 605-275-3600 Fax: 605-275-9595 VerlynHahn@HahnFinancialGroup.com O C T O B E R 1 6 , 2 0 2 5 This brochure supplement provides information about Verlyn Earl Hahn and supplements the Hahn Financial Group, Inc.’s brochure. You should have received a copy of that brochure. Please contact Hahn Financial Group, Inc. if you did not receive the brochure or if you have any questions about the contents of this supplement. Additional information about Verlyn Earl Hahn (CRD #1590372) is available on the SEC’s website at www.adviserinfo.sec.gov. - 20 - Hahn Financial Group, Inc.  Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Principal Executive Officer Verlyn Earl Hahn, CFP® ChFC® CLU® • Educational Background and Business Experience Year of birth: 1960 Educational Background: • • • • CFP Designation; 2006 ChFC Designation; 2006 CLU Designation; 2005 LUTCF; 1988 Professional Certifications Employees have earned certifications and credentials that are required to be explained in further detail. ® ): Certified Financial Planner is a designation granted ® ® Certified Financial Planner (CFP • by the CFP Board. CFP requirements: ® • Completion of the financial planning education requirements set by the CFP Board (www.cfp.net). ® • Successful completion of the 10-hour CFP Certification Exam. • Three-year qualifying full-time work experience. • Successfully pass the Candidate Fitness Standards and background check. ® When you achieve your CFP designation, you must renew your certification every two years, pay an annual certification fee and complete 30 hours of continuing education every two years. ® ® ® (ChFC ): Chartered Financial Consultant (ChFC ) is a ® • Chartered Financial Consultant designation issued by the American College. ChFC designation requirements: ® • Complete ChFC coursework within five years from the date of initial enrollment. • Pass the exams for all required elective courses. A minimum score of 70% must be achieved to pass. • Meet the experience requirements: Three years of full-time business experience within the five years preceding the date of the award. An undergraduate or graduate degree from an accredited educational institution qualifies as one year of business experience. • Take the Professional Ethics Pledge. ® designation, you must earn 30 hours of continuing When you achieve your ChFC education credit every two years. ® ): Chartered Life Underwriter is a designation granted ® • Chartered Life Underwriter (CLU by the American College. CLU designation requirements: ® coursework: five required and three elective Successfully complete CLU courses. - 21 - Hahn Financial Group, Inc.  • • Meet the experience requirements: Three years of business experience immediately preceding the date of the use of the designation are required. An undergraduate or graduate degree from an accredited education institution qualifies as one year of business experience. (Mr. Hahn was grandfathered for this requirement as he received his certification prior to this requirement) • Take the Professional Ethics Pledge. ® designation, you must complete 30 hours of When you achieve the CLU continuing education credit every two years. • Business Experience: • • • • • • • • • • • Other Business Activities Engaged In Hahn Financial Group, Inc.; President/Investment Advisor Representative; 01/2014-Present Hahn Financial Group, Inc.; Insurance Agent; 10/2006-Present Wisconsin Lutheran College; Member Board of Regents; 10/2023-Present Marvin M. Schwan Charitable Foundation; Trustee; 10/2021-Present Employer Referral Group, LLC; Managing Member; 02/2013-Present Gradient Securities, LLC; Registered Representative; 01/2014-12/2014 American United Life; Insurance Agent; 11/2006-01/2014 OneAmerica Securities; Investment Advisor Representative; 11/2006-1/2014 OneAmerica Securities; Registered Representative; 11/2006-12/2013 Thrivent Financial Bank; Solicitor; 07/2002-10/2006 Thrivent Investment Management Inc.; Managing Partner; 07/2002-10/2006 Thrivent Financial for Lutherans; Insurance Agent; 07/2002-10/2006 Verlyn Hahn has a financial industry affiliated business as an insurance agent. Approximately 30% of his time is spent in this business. From time to time, he offers clients advice or products from those activities. Clients are not required to purchase any products. Mr. Hahn also serves as a member of the Board of Regents for Wisconsin Lutheran College. He spends minimal time on this activity. These practices represent conflicts of interest because they give an incentive to recommend products and services based on the commission or fee amount received. This conflict is mitigated by disclosures, procedures, and the firm’s Fiduciary obligation to place the interests of the client first and clients are not required to purchase any products or services. Clients have the option to purchase these products or services through another insurance agent or other professional of their choosing. Additional Compensation Mr. Hahn is also a trustee of the Marvin M. Schwan Charitable Foundation. He spends a minimal amount of time on this activity. The foundation is not a client of the firm. Mr. Hahn receives additional compensation as a trustee of the Marvin M. Schwan Charitable Foundation. Mr. Hahn also receives a stipend for his role as member on the Board of Regents at Wisconsin Lutheran College. He does not receive any performance- based fees. - 22 - Hahn Financial Group, Inc.  Disciplinary Actions Supervision None to report. Verlyn Hahn is supervised by Kelly Hahn, but as the President of Hahn Financial Group, Inc. he is responsible for the formulation and monitoring of investment advice offered to clients. He will adhere to the policies and procedures as described in the firm’s Compliance Manual. - 23 - Hahn Financial Group, Inc.