Overview
Assets Under Management: $197 million
Headquarters: KNOXVILLE, TN
High-Net-Worth Clients: 110
Average Client Assets: $1 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (2025-08-15 RETIREMENT PLANNING SERVICES FORM ADV PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $3,000,000 | 0.70% |
| $3,000,001 | $5,000,000 | 0.50% |
| $5,000,001 | and above | 0.30% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $34,000 | 0.68% |
| $10 million | $49,000 | 0.49% |
| $50 million | $169,000 | 0.34% |
| $100 million | $319,000 | 0.32% |
Clients
Number of High-Net-Worth Clients: 110
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 75.50
Average High-Net-Worth Client Assets: $1 million
Total Client Accounts: 492
Discretionary Accounts: 492
Regulatory Filings
CRD Number: 289847
Last Filing Date: 2025-02-18 00:00:00
Website: https://confidenceandrest.com
Form ADV Documents
Primary Brochure: 2025-08-15 RETIREMENT PLANNING SERVICES FORM ADV PART 2A (2025-08-15)
View Document Text
Hall Retirement Planning Services, LLC
Item 1: COVER PAGE
Hall Retirement Planning Services, LLC
4533 Papermill Dr
Suite 101
Knoxville, TN 37909
Phone: 865-220-9311
Fax: 865-220-9316
www.seriousretirement.com
Form ADV Part 2A Brochure
This brochure provides information about the qualifications and business practices of Hall
Retirement Planning Services, LLC. If you have any questions about the contents of this
Brochure, please contact us at 865-220-9311 and/or spencer@confidenceandrest.com. The
information in this Brochure has not been approved or verified by the United States Securities
and Exchange Commission or by any state securities authority.
Additional information about Hall Retirement Planning Services, LLC also is available on the
SEC’s website at www.adviserinfo.sec.gov. The searchable Advisory Representative/CRD
number for Hall Retirement Planning Services, LLC is 289847.
Any references to Hall Retirement Planning Services, LLC as a registered investment adviser
or its related persons as registered Advisory Representatives does not imply a certain level of
skill or training.
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Hall Retirement Planning Services, LLC
Item 2: MATERIAL CHANGES
At least annually, this section will discuss only specific material changes that are made to the
Brochure and provide you with a summary of such changes. Since the last annual update to this
Brochure filed on January 30, 2024, we have no material changes to report.
A copy of our updated Brochure and Brochure Supplements is available to you free of charge and
may be requested by contacting us at 865-220-9311 and/or spencer@confidenceandrest.com.
Additional information about Hall Retirement Planning Services, LLC is also available via the
SEC’s website www.adviserinfo.sec.gov. The IARD number for Hall Retirement Planning Services,
LLC is 289847. The SEC’s website also provides information about any persons affiliated with Hall
Retirement Planning Services, LLC who are registered, or are required to be registered, as Advisory
Representatives of Hall Retirement Planning Services, LLC.
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Item 3: TABLE OF CONTENTS
1
2
3
4
10
13
14
15
18
19
Item 1: COVER PAGE
Item 2: MATERIAL CHANGES
Item 3: TABLE OF CONTENTS
Item 4: ADVISORY BUSINESS
Item 5: FEES AND COMPENSATION
Item 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Item 7: TYPES OF CLIENTS
Item 8: METHODS of ANALYSIS, INVESTMENT STRATEGIES and RISK of LOSS
Item 9: DISCIPLINARY INFORMATION
Item 10: OTHER FINANCIAL INDUSTRY ACTIVITIES and AFFILIATIONS
Item 11: CODE of ETHICS, PARTICIPATION or INTEREST in CLIENT TRANSACTIONS and
PERSONAL TRADING
Item 12: BROKERAGE PRACTICES
Item 13: REVIEW of ACCOUNTS
Item 14: CLIENT REFERRALS and OTHER COMPENSATION
Item 15: CUSTODY
Item 16: INVESTMENT DISCRETION
Item 17: VOTING CLIENT SECURITIES
Item 18: FINANCIAL INFORMATION
20
21
22
23
24
25
26
27
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Hall Retirement Planning Services, LLC
Item 4: ADVISORY BUSINESS
Hall Retirement Planning Services, LLC (hereinafter referred to as “RPS”) is a financial planning
and investment advisory firm offering wealth management services customized to your individual
needs.
A.
In 1985, Retirement Planning Services, LLC (RPS), was founded by Steven Hall. Spencer
Hall joined his father, Steven, in the family business in 2010. RPS was registered as an investment
adviser from 2004 until 2017. In 2012, Spencer became a Managing Partner of RPS along with
Steven. In 2017, when Spencer was ready to take the lead in the business, Hall Retirement Planning
Services, LLC was formed under the laws of the State of Tennessee as a continuation of the family
business, still doing business as Retirement Planning Services. Spencer Hall, CRD number
5821183, is the owner of the firm. Spencer Hall serves as President and an Advisory Representative
of RPS. He has been in the financial services industry since 2010. Additional business information
about Spencer is disclosed in the Supplemental Brochure attached to this Brochure.
B.
RPS offers the following advisory services, with each service more fully described below:
● Financial Planning
● Asset Management Services
Financial Planning Services
Our mission is to educate and equip clients to make wise financial decisions that align their wealth
with their values through exceptional financial planning and investment management. We initially
meet with potential clients to determine if a working relationship would be a good fit. In the first
meeting we listen to understand what services the potential client desires and what expectations the
client has in considering working with our team. If we feel that we have the capacity to meet a
potential client’s expectations and fulfill the services desired, we typically offer to mutually explore
working together by taking up to two more meetings without charge.
We begin this exploratory process by verbally gathering information from you. We ask questions
about your biographical and financial background and want to understand your personal and
financial goals and your values. We gather additional financial information and history from you
about your retirement goals, investment horizon, cash flow needs, education spending plans, savings
tendencies, and other applicable financial information to provide the planning services you request.
Through a series of questions and dialogue, we also work to understand your expectations, your
tolerance for risk, the way that you have invested in the past, the assets you have accumulated, and
how they are currently invested. We also ask that you bring statement copies of any investments you
have to the meeting.
At the end of the third meeting together, if both our team and the potential client agree to continue
the financial planning process, our team will walk you through a financial planning agreement and
specify a fee for the financial plan, or if you are prepared to invest with our team, we may waive the
financial planning fee and engage in an asset management agreement.
We will work together with you to build a collaborative, written financial plan. This typically
includes building a personal balance sheet, a series of hypothetical scenarios to understand
cash-flow, retirement savings, and investment account value potential outcomes (given a variety of
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different assumptions), and determining an asset allocation with an appropriate amount of fixed
income and equity investments based on a net present value calculation, given your tolerance for
risk. The financial plan includes an analysis of how to locate particular assets to help reduce the tax
drag on your portfolio. We also offer to review your former year tax filing to assess if any
investment changes in allocation (e.g. maintaining municipal bonds in after-tax accounts),
investment vehicle (e.g. opening a health savings account), or distribution strategy (e.g. executing a
qualified charitable distribution from an IRA) might be explored further. We may evaluate one or
more years of prior 1040s and supporting documents to inform present tax-planning decisions and
identify planning opportunities and areas of concern for the current and future periods. Because we
have no Certified Public Accountants (CPAs) or Enrolled Agents (EAs) on our team, the client
should not expect “tax advice” – meaning an opinion from a federally authorized tax practitioner
who could prepare returns and defend the client in front of the Internal Revenue Service. Instead,
any planning areas identified should be discussed with your CPA or EA.
If you are facing a pension election decision or Social Security benefit decision within the next two
years, we will also typically collaborate on a series of hypothetical scenarios particular to those
decisions that will equip you to see a range of possible outcomes.
We will also educate you on an evidence-based approach to managing investments and
psychological pitfalls that snare many investors related to their investment behaviors. We will work
with you to build a strategy for your distributions and assess if other strategies (e.g. Roth conversion)
would be advisable and present the analysis of your situation along with potential steps to be taken
to assist you to work toward your financial goals.
The Plan is based on your financial situation at the time and on the financial information you
disclosed to our Advisory Representative. We will collaborate with you on the planning assumptions
that will be made with respect to portfolio rates of return, inflation rates, cost of living adjustment
changes for Social Security and pensions, and a variety of other variables. However, past
performance is in no way an indication of future performance. RPS cannot offer any guarantees or
promises that your financial goals and objectives will be met. If you solely engage us for a financial
planning agreement, you will be responsible for all implementation of recommendations.
If you engage our team in helping you manage your assets after completing the financial plan, we
offer to update the financial planning projections at least annually, but you must continue to review
the plan and collaborate with us to update the plan based upon changes in your financial situation,
goals, or objectives or changes in the economy. If your financial situation or investment goals or
objectives change, you must notify RPS promptly of the changes. You are advised that the
advice offered by RPS is limited and is not meant to be comprehensive. When appropriate to your
specific needs or situation, you will need to seek the services of other professionals such as an
insurance adviser, attorney and/or accountant.
Asset Management Services
RPS will collaborate with you to develop an asset allocation strategy consistent with your
investment objectives, financial and tax status, risk tolerance and time horizon. Each asset
allocation strategy consists of either an agreed-on percentage mix of fixed income and equity
investments or a target amount of fixed income investments to be maintained when the account is
rebalanced near stock market highs. The fixed income allocation may include one or more of the
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following: (a) cash; (b) money market funds; (c) U.S. government securities; (d) foreign
government bonds; (e) U.S. corporate debt; (f) foreign corporate debt; (g) municipal securities; (h)
fixed income mutual funds; (i) fixed income ETFs and ETNs, and (j) any other appropriate fixed
income investment. The equity portion of the allocation may include one or more of the following:
(a) individual stocks that are exchange listed; (b) individual stocks that are traded over-the-counter;
(c) individual stocks issued by foreign corporations; (d) equity, REIT and MLP mutual funds; (e)
variable annuity sub-accounts (with fee-based providers like TIAA-CREF and Jefferson National)
products; (f) equity, REIT and MLP ETFs and ETNs; and (g) any other appropriate equity
investment. Where appropriate, fee-only fixed indexed annuities may also be included in the asset
allocation - typically to provide a fixed rate of return with other guaranteed insurance benefits. For
certain clients (that are typically accredited investors, qualified clients, and/or qualified
purchasers), we will also offer investments into select private investment funds available through
the platform of the custodian we recommend to clients (primarily for missional impact
investments). Recommended mutual funds may be no-load or load-waived. If you strongly desire
to defer as much taxation as possible, your Advisory Representative may also recommend a
no-commission, flat-fee variable annuity platform where investments can be located.
Once the basic asset allocation strategy is determined, and you approve the new target asset
allocation, your existing assets may be liquidated (or transferred into the appropriate account) and
invested into the chosen investment vehicles. Our team will walk you through the process of
transferring resources (whether the transfer requires paperwork, telephone call(s), or other actions).
Reallocation of your assets will trigger taxable events except where Individual Retirement
Accounts, 401(k) Accounts, 403(b) Accounts, 457 Accounts or other qualified retirement plans or
accounts are involved. As resources transfer into accounts that are managed by our team, we will
implement the asset allocation strategy.
After we implement the initial portfolio allocation, with your written approval as indicated in the
Advisory Agreement, we will manage your account on a continuous and ongoing basis, using our
own discretion to determine any changes to the account. Unless otherwise expressly requested by
you, RPS will manage the account and will make changes to the allocation as deemed appropriate by
the firm and your Advisory Representative. You will receive a confirmation for all securities
transactions in your account (buys and sells). RPS will determine the securities to be purchased and
sold in the account and will alter the securities holdings from time to time, without prior consultation
with you.
When managing your account, and in an effort to better coordinate your tax planning and estate
planning needs, our team may refer you to a select person or firm to assist with annual tax filing
preparation and/or estate planning document preparation and updates. RPS may elect to pay on your
behalf the cost of preparing and filing the annual, personal tax return. RPS may also elect to pay the
cost of preparing and updating estate planning documents – Will, Living Will, Powers of Attorney,
and Trust or Amendment to Trust. If you grant authorization, RPS and the select individual or firm
providing the services will share your personal, non-public information.
In order to share your information with the select individual or firm providing tax or estate planning
services, you must first provide us with written authorization by signing the addendum to our Asset
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Management Agreement. The tax preparer, CPA, attorney, or individual designated are not
employees of or affiliated with RPS. RPS receives no remuneration for such referrals.
Selection of Other Investment Advisers
From time to time and when appropriate for a particular client, RPS will recommend or retain an
independent and unaffiliated third-party investment adviser (“Third-Party Adviser”) to manage all or
a portion of a client’s portfolio (which will generally be on a discretionary basis). Third-Party
Advisers are evaluated based on a variety of factors, not the least of which include performance
return history, asset class specialization, management tenure, and risk profile. RPS will conduct due
diligence as appropriate to confirm that such Third-Party Advisers are duly registered and otherwise
well-equipped to manage such clients’ accounts. RPS generally retains the discretionary authority to
hire or fire such Third-Party Advisers with or without notice to the client, but will work in
collaboration with you to the extent RPS believes the retention of a Third-Party Adviser is
appropriate for your financial situation.
C. We tailor the advisory services we offer to your individual needs. Your specific information
is obtained during our in-person-interviews. The information gathered by RPS will assist the firm in
providing you with the requested services and customize the services to your financial situation.
Depending on the services you have requested, we will gather various financial information and
history from you including, but not limited to:
● Retirement and financial goals
● Investment objectives
● Investment horizon
● Financial needs
● Cash flow analysis
● Cost-of-living needs
● Education needs
● Savings tendencies
● Other applicable financial information required by our Advisory Representative to
provide the investment advisory services you have requested.
The software we currently subscribe to for assistance in planning includes Social Security Timing,
Morningstar Direct, and Tax Clarity.
D.
RPS does not participate in any wrap fee programs.
When we provide investment advice to you regarding your retirement plan account or
E.
individual retirement account, we are fiduciaries within the meaning of Title I of the Employee
Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (the “Code”), as
applicable, which are laws governing retirement accounts. The way we make money creates some
conflicts with your interests, so we operate under a special rule that requires us to act in your best
interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
I. Meet a professional standard of care when making investment recommendations (give
prudent advice);
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II. Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
III. Avoid misleading statements about conflicts of interest, fees, and investments;
IV.
Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
V. Charge no more than is reasonable for our services; and
VI. Give you basic information about conflicts of interest.
F.
As of December 31, 2024, we have approximately $196,619,523 of client assets under our
discretionary management. We have $0 of client assets under our non-discretionary management.
General Information
Financial planning and investment advisory services offered by RPS and Advisory Representatives
do not constitute legal or accounting advice. From time to time, we will suggest items to review
with your CPA or attorney and investment actions to consider which may impact your tax situation,
but we are not licensed to practice law, nor to represent clients before the IRS, nor serve as an
accountant. We do not compose any estate planning documents (will, living will, power of attorney,
trusts, etc.) for clients. You should coordinate and discuss the impact of financial advice with your
attorney and/or accountant. Our primary goal is to help our clients identify and pursue their
financial goals, thereby enhancing the overall quality of their lives.
IRA Rollover Considerations
As part of our consulting and advisory services, we provide you with recommendations and advice
concerning your employer retirement plan or other qualified retirement account. When appropriate,
we recommend that you withdraw the assets from your employer's retirement plan or other qualified
retirement account and roll the assets over to an individual retirement account ("IRA") that we will
manage. If you elect to roll the assets to an IRA under our management, we will charge you an
asset-based fee as described in Item 5. This practice presents a conflict of interest because our
investment advisory representative has an incentive to recommend a rollover to you for the purpose
of generating fee-based compensation rather than solely based on your needs. You are under no
obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the
rollover, you are under no obligation to have your IRA assets managed by us. You have the right to
decide whether or not to complete the rollover and the right to consult with other financial
professionals.
Some employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire or
change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of each.
An employee will typically have four options:
1. Leave the funds in your employer's (former employer's) plan.
2. Roll over the funds to a new employer's retirement plan.
3. Cash out and take a taxable distribution from the plan.
4. Roll the funds into an IRA rollover account.
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Each of these options has advantages and disadvantages. Before making a change, we encourage you
to speak with your CPA and/or tax attorney.
Before rolling over your retirement funds to an IRA for us to manage, carefully consider the
following. NOTE: This list is not exhaustive.
1. Determine whether the investment options in your employer's retirement plan address your
needs or whether other types of investments are needed.
a. Employer retirement plans generally have a more limited investment menu than IRAs.
b. Employer retirement plans may have unique investment options not available to the
public such as employer securities or previously closed funds.
2. Your current plan may have lower fees than our fees.
a. If you are interested in investing only in mutual funds, you should understand the cost
structure of the share classes available in your employer's retirement plan and how the
costs of those share classes compare with those available in an IRA.
b. You should understand the various products and services available through an IRA
provider and their costs.
c. It is likely you will not be charged a management fee and will not receive ongoing asset
management services unless you elect to have such services. If your plan offers
management services, the fee associated with the service may be more or less than our
asset management fee.
3. Our strategy may have higher risk than the option(s) provided to you in your plan.
4. Your current plan may offer financial advice, guidance, management, and/or portfolio options
at no additional cost.
5. If you keep your assets titled in a 401k or retirement account, and you are still working, you
could potentially delay your required minimum distribution beyond age 70.5 (70 ½).
6. Your 401k may offer more liability protection than a rollover IRA; each state may vary.
Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets
have been generally protected from creditors in bankruptcies; however, there can be
exceptions. Consult an attorney if you are concerned about protecting your retirement plan
assets from creditors.
7. You may be able to take out a loan on your 401k, but not from an IRA.
8. IRA assets can be accessed any time; however, prior to age 59 ½, distributions are subject to
ordinary income tax and may also be subject to a 10% early distribution penalty unless they
qualify for an exception such as disability, higher education expenses, or a home purchase.
9. If you own company stock in your plan, you may be able to liquidate those shares at a lower
capital gains tax rate.
10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name.
It is important that you understand your options, their features and differences and decide whether a
rollover is best for you. If you have questions, contact one of our Advisory Representatives at our
main number listed on the cover page of this brochure.
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Item 5: FEES AND COMPENSATION
Financial Planning Services
Fees for planning services are strictly for planning services. Therefore, if you execute a financial
plan, you should expect to pay fees for additional services obtained through RPS (such as asset
management) and products purchased through third-parties (such as insurance).
Planning fees are negotiated at the discretion of your Advisory Representative and are either fixed or
based on a maximum hourly rate of $500 /hour for Advisory Representatives’ time and $100 for
clerical services time. Your fees will be dependent on several factors including time spent with RPS,
number of meetings, complexity of your situation, amount of research, services requested and/or
staff resources. The fee is payable at the presentation of the financial plan or as invoiced by RPS.
We may waive our fee for clients that sign up for our asset management services. If you are
unsatisfied with the plan or feel that you did not gain from the delivery of the plan, you may receive
a full refund of compensation paid for the financial plan by notifying your Advisory Representative
within seven days of the delivery of the final plan.
Asset Management Services
The maximum annual fee for participation in the asset management services program is 1.00% and
is negotiable. Fees for this service are paid quarterly in arrears.
Your advisory fees will be deducted from your account when due on a quarterly basis. Money
market shares will be liquidated to pay the fees and, if insufficient money market shares or cash are
available, other investments will be liquidated to pay the fees. The investment(s) to be liquidated
will be selected by your Advisory Representative. Authorization for the automatic deduction of
fees from your account(s) is contained in our Advisory Agreement.
Fees are calculated on your account(s) in accordance with your client agreement on a quarterly
basis. The fee is calculated based upon the average daily value of your account computed and
payable in arrears during the preceding month or quarter.
RPS’s standard fee schedule is as follows:
Maximum Annual Fee
Account Size
First $1,000,000
Next $2,000,000
Next $2,000,000
Over $5,000,000
1.00%
0.70%
0.50%
0.30%
Note: Our annual asset management fee is based on an aggregate value of all accounts within the
established household as reported by the custodian of your account(s), inclusive of the gross value of
securities and cash (including private investment funds).
We sometimes make exceptions to our general fee schedule under certain circumstances (e.g.,
responsibilities involved; accounts or groups of accounts that are expected to have significant capital
additions in the future; anticipated future earning capacity; related accounts; account composition;
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pre-existing client; account retention; pro bono activities; etc.). In such cases, lower fees or different
payment arrangements can be negotiated with each client separately and will be described in the
client’s Investment Advisory Agreement.
In particular, we charge pursuant to the following fee schedule with respect to certain assets like
fee-based equity-indexed annuities with living benefit riders:
Maximum Annual Fee
Account Size
First $1,000,000
Next $2,000,000
Over $3,000,000
0.70%
0.50%
0.30%
We charge pursuant to the following fee schedule with respect to certain assets like fee-based
multi-year annuities with no living benefit income stream and/or limited investment options, as
well as for 529 education savings plan accounts and certificates of deposit:
Maximum Annual Fee
Account Size
First $1,000,000
Next $2,000,000
Over $3,000,000
0.50%
0.40%
0.30%
The assets and accounts subject to both of the non-standard fee schedules listed immediately above
shall be aggregated with the assets and accounts subject to the standard fee schedule for purposes
of determining whether the client is entitled to any fee breakpoints in the applicable fee schedule.
In other words, the non-standard fee schedules listed immediately above shall never result in a
higher aggregate fee charged to the client. To the extent an asset type described in one of the
non-standard fee schedules listed above is held in the same account(s) that hold other asset types
subject to the standard fee schedule, such non-standard asset types (e.g., certificates of deposit)
shall be charged pursuant to the applicable non-standard fee schedule and the remaining assets
within the same account shall be charged pursuant to the standard fee schedule.
Since our fee schedule can vary based on a client’s account types and the types of investment
products into which a client has invested, RPS has an incentive to recommend account types and
investment products that result in higher compensation to us. RPS addresses this conflict of interest
by fully disclosing it in this Brochure, by aggregating all asset and account values for purposes of
applying available fee breakpoints, and by always making investment product and account type
recommendations that are in the best interests of clients.
You will generally be responsible for any and all transaction charges, including standard
broker-dealer ticket charges and confirmation fees, wire transfer fees, and other fees which may be
assessed to your account. You will pay separately for IRA custodial services and may be assessed
inactivity fees. All fees paid to RPS for investment advisory services are separate from fees and
expenses charged to owners of mutual fund shares or variable annuity contracts by the product
sponsors. As a result, you may pay two management fees. Variable Annuities often carry higher
internal expense ratios than mutual fund investments due to their insurance related features. If you
opt for management of a variable annuity, you will be subject to higher annual fees than if only
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invested in the variable annuity, as fees paid to RPS are separate and segregate from the annuity
expenses. Furthermore, you will have the same investment options and could possibly invest in a
similar fashion without management services on their own. A complete explanation of the
product-related fees and expenses is contained in the prospectus for the particular investment
product.
Except for the direct debit of asset management services described above, we will provide you with
an invoice that is payable upon receipt for our advisory services. If your advisory account is
established or closed during the middle of a month, you will pay a pro-rated portion of the advisory
fee based upon the number of days the account was under RPS’ review and management.
In addition to the advisory fees above, you will pay transaction fees for securities transactions
executed in your account in accordance with the custodian’s transaction fee schedule. You may also
pay fees for custodial services, account maintenance fees, and other fees associated with maintaining
the account. These fees are not charged by RPS and are charged by the product, broker/dealer or
account custodian. RPS does not share in any portion of these fees. Additionally, you may pay your
proportionate share of the fund’s management and administrative fees and sales charges as well as
the mutual fund adviser’s fee of any mutual fund they purchase. These advisory fees are not shared
with RPS and are compensation to the fund manager. More information is available in the mutual
fund prospectus. To the extent a Third-Party Adviser is retained to manage all or a portion of your
account(s), the Third-Party Adviser will generally charge an additional asset-based fee directly to
you in consideration of its investment management services. This additional asset-based fee, as well
as the mechanics of how the additional asset-based fee will be charged, will be disclosed to you at
the time the Third-Party Adviser is to be engaged. As of the date of this brochure, the additional
asset-based fee can range up to 0.60% per year of assets designated to be under the management of
the Third-Party Adviser. RPS does not share in the fees charged by a Third-Party Adviser.
Generally, fees are billed as services are provided. However, depending upon the scope of
consulting services requested, a retainer fee may be required. In no instance, however, will RPS
charge more than $1,200, six or more months in advance.
RPS may change the above fee schedule upon 30-days prior written notice to you.
Termination Provisions
You may terminate advisory services obtained from RPS, without fee or penalty, with written notice
to RPS within five (5) business days after entering into the advisory agreement with RPS.
Thereafter, you may terminate advisory services with written notice to RPS. You will be responsible
for any time spent by RPS in providing you advisory services or analyzing your situation. Any
unearned, pre-paid fees will be refunded to you within thirty (30) days of receipt of the written
termination request.
RPS may terminate the advisory agreement at any time upon written notice to the client.
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Item 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
RPS does not charge performance-based fees and therefore does not engage in side-by-side
management.
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Hall Retirement Planning Services, LLC
Item 7: TYPES OF CLIENTS
RPS’s services are geared toward both high-net-worth individuals and non-high-net-worth
individuals as well as charitable organizations, corporations, and other business entities. RPS does
not require a minimum amount of client assets to be under our management to open or maintain an
account. However, a Third-Party Adviser retained to manage all or a portion of your account(s) may
impose a minimum account fee or otherwise require a minimum amount of your assets to be
designated under the Third-Party Adviser’s management.
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RPS conducts economic analysis and attempts to analyze and determine the economic trends.
Item 8: METHODS of ANALYSIS, INVESTMENT STRATEGIES and RISK of LOSS
A.
Such analysis is based on third-party research, and typically encompasses a variety of data points
that inform its decision-making with respect to client accounts. Based on such research and analyses,
RPS typically constructs a diversified portfolio of equity and fixed income investments that are
in-line with a client’s stated investment objectives, risk tolerance, and other factors. Such portfolios
are thereafter managed on an ongoing basis based on a client’s specific needs.
Investing in securities involves risk of loss, including the potential loss of the principal
B.
money you are investing. Therefore, your participation in our asset management services requires
you to be prepared to bear the risk of loss as well as the fluctuating performance of your accounts.
Market values of investments will fluctuate based on market conditions.
We do not represent, warrantee or imply that the services or methods of analysis we use can or will
predict future results, successfully identify market tops or bottoms or insulate you from losses due to
major market corrections or crashes. Past performance is no indication of future performance. No
guarantees can be offered that your goals or objectives will be achieved. Further, no promises or
assumptions can be made that the advisory services offered by RPS or our Advisory Representatives
will provide a better return than other investment strategies.
The primary risk factors applicable to our investment program generally include:
• Market risk–The price of a security, bond, mutual fund and/or exchange-traded
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
circumstances. For example, economic, political and social conditions may trigger
market-related events.
• Interest rate risk–The chance that investment prices will change based on a
move in interest rates (bond prices decline as interest rates rise). Relative to fixed
income securities with near-term maturities, longer maturity bonds will have a larger
change in price with a move in interest rates.
• Inflation risk–The risk that investment returns will be below the general increase in
prices due to inflation.
• Category or style risk–The chance that one investment category or style may
underperform or outperform other categories and styles.
• Credit risk–The chance that a bond issuer will fail to pay interest and principal in a
timely manner.
• Reinvestment risk–The potential exposure 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.
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• Early redemption risk–Some bonds have features that allow the bond issuer to
repurchase or redeem the bond before maturity at a specific price. This risk is the
chance that the borrower will do so; thus, expose the investor to a lower than
expected return on that bond investment.
• Systematic risk–Also known as "market risk," this is the chance of a severe drop of an
entire financial market (e.g., political or social upheaval, natural disaster, etc.).
• Unsystematic risk–Also known as "specific risk," this is the chance of a decline in the
value of a particular asset (i.e., an individual stock declines while the overall stock
market is not impacted).
• Currency risk–Also known as "exchange rate risk," this is the chance that foreign
investments will be subject to fluctuations in the value of the dollar against the
currency of the investment's country of origin.
• Tax risk–This is the chance that the taxing authority changes its tax rates or policies
(e.g., rescind tax-exempt status of particular bonds).
• Liquidity risk–This is the risk whereby the ability to buy or sell a security becomes
more difficult and, therefore, negatively impacts the price at which one is able to
transact in the security.
• Financial risk–Excessive borrowing to finance the ongoing operations of a business
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 declining market value.
• Sector risk–This is the chance that major problems may impact a specific sector, or
that returns from that sector may trail the returns of the overall equity market.
Daily fluctuations in individual sectors can often be more extreme than fluctuations in
in the overall market.
• Price volatility–The price of a security, mutual fund and/or exchange-traded fund
may fluctuate, even significantly, in a short period of time.
• Exchange-traded fund pricing risk–Exchange-traded fund shares may trade in the
market at a premium or discount to their net asset (NAV) because of market supply
and demand. The premiums and discounts for specific exchange-traded funds can
vary, depending on the type of exchange-traded fund and time period.
Mutual funds are often used in client portfolios. The risks with mutual funds include the
C.
costs and expenses within the fund that can impact performance, change of managers and/or the fund
straying from its stated investment objective. Open-ended mutual funds do not typically have a
liquidity issue and the price does not fluctuate throughout the trading day. Mutual fund fees are
described in the fund's prospectus, which the custodian mails directly to the client following any
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purchase of a mutual fund that is new to the client’s account. In addition, a prospectus is available
online at each mutual fund company’s website. At the client's request, RPS will direct the client to
the appropriate Web page to access the prospectus.
RPS may also use ETFs in our portfolios. The risks with ETFs include the fact that actively traded
ETFs can create increased trading expenses and fees and the intraday trading opportunities created
by ETFs may not fit into a long-term investor’s strategy. ETFs are usually easy to buy and sell.
An interval fund is a type of closed-end fund that periodically offers to repurchase its shares from
shareholders. Shareholders are not required to accept these offers and sell their shares back to the
fund. Shares typically do not trade on the secondary market. Instead, their shares are subject to
periodic repurchase offers by the fund at a price based on net asset value. Interval funds are
permitted to deduct a redemption fee from the repurchase proceeds, not to exceed 2% of the
proceeds. The fee is paid to the fund, and generally is intended to compensate the fund for expenses
directly related to the repurchase. Interval funds may charge other fees as well. In addition to the
risks associated with pooled investment vehicles generally as described above, the specific risk
associated with interval funds is that it is less liquid than other open-end mutual funds that can
generally be redeemed at any time. Thus, a client may not be able to redeem his or her investment
until a redemption window is available.
Investments in private investment funds (e.g., limited partnerships, limited liability companies,
special purpose vehicles, and other private investment funds) are often subject to liquidity
restrictions, which means that a client may not be able to redeem his or her investment until a
redemption window is available. In addition, such investments can be more volatile and less
transparent than an exchange-listed security that trades daily in an electronic marketplace. Private
investment funds are generally more difficult to value than exchange-listed securities, and therefore
are more reliant on individual judgment as opposed to market prices when determining a valuation.
Investors in private investment funds are typically required to be either accredited investors,
qualified clients, or both, and should carefully consider the specific risks described in the applicable
private placement memorandum, limited partnership agreement, limited liability company
agreement, and other fund-related disclosure documents.
Relying on the investment advisory or management services of an independent and unaffiliated
third-party adviser means that clients will be subject to such third-party adviser’s continued ability to
achieve its investment mandates, as well as specific client investment objectives and restrictions. To
the extent that a third-party adviser is dependent on the services or intellectual capital of a select few
individuals, the departure or death of such individuals may have a material impact on the continued
viability of such third-party adviser and its ability to continue serving client accounts. There can be
no guarantee that a third-party adviser will meet its performance expectations, or that its services
will be free of trading or management-related errors.
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Item 9: DISCIPLINARY INFORMATION
There is no reportable disciplinary information required for RPS or its management persons that is
material to your evaluation of RPS, its business or its management persons.
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RPS does not have a related person who is a: broker/dealer or other similar type of broker or
Item 10: OTHER FINANCIAL INDUSTRY ACTIVITIES and AFFILIATIONS
A.
dealer; investment company or other pooled investment vehicle, other investment adviser or
financial planner; futures commission merchant or commodity pool operator; banking or thrift
institution; accountant or accounting firm; lawyer or law firm; insurance company or agency;
pension consultant; real estate broker or dealer; or sponsor or syndicator of a limited partnership.
RPS and its Advisory Representatives are not actively engaged in any other financial industry entity.
B. As described earlier in Item 4 of this brochure, RPS retains the authority to recommend or
retain one or more Third-Party Advisers to manage all or a portion of a client’s account(s). RPS does
not receive any compensation directly from such Third-Party Adviser.
From time to time and when appropriate for a particular client, RPS will recommend the
C.
services of DPL Financial Partners, LLC (“DPL”), an independent and unaffiliated third-party
insurance platform through which clients can obtain commission-free insurance products. RPS pays
an annual membership fee to DPL to facilitate client access to the DPL platform. In connection with
its membership, RPS also receives analyses of our current methodology for evaluating client
insurance needs, educating and acting as a resource regarding insurance products generally and
specific insurance products owned by or under consideration by clients, and providing access to, and
marketing support for, commission-free products that insurers have agreed to offer to our clients
through DPL’s platform. This relationship is not anticipated to present any conflicts of interest, as
RPS does not share in any premiums or other revenue earned by DPL, and does not charge or
otherwise earn any commissions for any insurance product.
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Item 11: CODE of ETHICS, PARTICIPATION or INTEREST in CLIENT TRANSACTIONS
and PERSONAL TRADING
Code of Ethics
A.
RPS has a fiduciary duty to you to act in your best interest and always place your interests
first and foremost. RPS takes seriously its compliance and regulatory obligations and requires all
staff to comply with such rules and regulations as well as our policies and procedures. Further, we
strive to handle your non-public information in such a way to protect information from falling into
the hands of anyone who has no business reason to know such information. We provide you with
our Privacy Policy which details our procedures for handling your personal information. RPS
maintains a Code of Ethics for its Advisory Representatives, supervised persons, and office staff.
The Code of Ethics contains provisions for standards of business conduct to comply with federal
securities laws, personal securities reporting requirements, pre-approval procedures for certain
transactions, code violations reporting requirements, and safeguarding of material non-public
information about your transactions. Further, our Code of Ethics establishes our firm’s expectation
for business conduct. A copy of our Code of Ethics will be provided to you upon request.
Neither RPS nor its associated persons recommends to clients or buys or sells for client
B.
accounts any securities in which we have a material financial interest.
C.
RPS and its associated persons may buy or sell securities identical to those securities
recommended to you. Therefore, RPS and/or its associated persons may have an interest or position
in certain securities that are also recommended and bought or sold to you. They will not put their
interests before your interests. Neither RPS nor any associated person may trade ahead of you or
trade in such a way to obtain a better price for themselves than for you or other clients.
RPS is required to maintain a list of all securities holdings for its associated persons and
D.
develop procedures to supervise the trading activities of associated persons who have knowledge of
your transactions and their related family accounts at least quarterly. Further, associated persons are
prohibited from trading on non-public information or sharing such information.
You have the right to decline to implement any investment recommendation. RPS and its associated
persons are required to conduct their investment advisory business in accordance with all applicable
Federal and State securities regulations.
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RPS considers several factors when recommending a custodial broker-dealer for client
Item 12: BROKERAGE PRACTICES
A.
transactions and determining the reasonableness of such custodial broker-dealer’s compensation.
Such factors include the custodial broker-dealer’s industry reputation and financial stability, service
quality and responsiveness, execution price, speed and accuracy, reporting abilities, and general
expertise. Assessing these factors as a whole allows RPS to fulfill its duty to seek best execution for
its clients’ securities transactions. However, RPS does not guarantee that the custodial broker-dealer
recommended for client transactions will necessarily provide the best possible price, as price is not
the sole factor considered when seeking best execution. After considering the factors above, RPS
recommends Fidelity Brokerage Services LLC (“Fidelity”) and Altruist Financial LLC ("Altruist")
as the custodial broker-dealers for client accounts. You are advised that not all investment advisers
require you to maintain accounts at a specific broker/dealer. You are advised you may maintain
accounts at another broker/dealer. However, the services provided by RPS will be limited to only
advice and will not include implementation. If you select another brokerage firm for custodial and/or
brokerage services you will not be able to receive asset management services from RPS.
In initially selecting Fidelity and Altruist, RPS conducted due diligence. Our evaluation and criteria
included ability to service you, staying power as a company, industry reputation, ability to report to
you and to us, trading platform, products and services available, technology resources, and
educational resources.
Periodically, we will review alternative broker/dealers and custodians in the marketplace to ensure
Fidelity and Altruist are meeting our duty to seek best execution for your accounts. The review will
include a comparison to Fidelity and Altruist which involves evaluating criteria such as overall
expertise, cost competitiveness and financial condition. The quality of execution by Fidelity and
Altruist will be reviewed through trade journal evaluations. However, best execution does not
simply mean the lowest transaction cost. Therefore, no single criteria will validate or invalidate a
custodian, but rather, all criteria taken together will be used in evaluating the current custodian.
RPS does not receive research and other soft dollar benefits in connection with client securities
transactions, which are known as “soft dollar benefits”. However, the custodial broker-dealers
recommended by RPS do provide certain products and services that are intended to directly benefit
RPS, clients, or both. Such products and services include (a) an online platform through which RPS
can monitor and review client accounts, (b) access to proprietary technology that allows for order
entry, (c) duplicate statements for client accounts and confirmations for client transactions, (d)
invitations to the custodial broker-dealer(s)’ educational conferences, (e) practice management
consulting, and (f) occasional business meals and entertainment. The receipt of these products and
services creates a conflict of interest to the extent it causes RPS to recommend Fidelity and Altruist
as opposed to a comparable broker-dealer. RPS addresses this conflict of interest by fully disclosing
it in this brochure, evaluating Fidelity and Altruist based on the value and quality of its services as
realized by clients, and by periodically evaluating alternative broker-dealers to recommend. RPS
does not consider, in selecting or recommending custodial broker-dealers, whether RPS or a related
person receives client referrals from a custodial broker-dealer or third-party.
Due to the individual management of client accounts, we do not aggregate the purchase or
B.
sale of securities for various client accounts.
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Item 13: REVIEW of ACCOUNTS
A.
If you are participating in our Asset Management Services, you will have reviews at least
annually or as agreed by you and your Advisory Representative. You may request more frequent
reviews. You are advised that you must notify your Advisory Representative promptly of any
changes to your financial goals, objectives or financial situation as such changes may require him to
review the portfolio allocation and make recommendations for changes. Reviews will be conducted
by Spencer Hall, President.
Your Advisory Representative will monitor for changes or shifts in the economy, changes to
B.
the management and structure of a mutual fund or company in which your assets are invested, and
market shifts and corrections.
You will be provided statements at least quarterly direct from the account custodian.
C.
Additionally, you will receive confirmations of all transactions occurring direct from the account
custodian.
If you are participating solely in Financial Planning Services, you will not receive regular account
reviews. RPS recommends you have at least an annual review and update to any plans. However,
the time and frequency of the reviews is solely your decision. Other than the initial plan or analysis,
there will be no other reports issued.
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RPS does not receive any monetary assistance from product vendors. Some vendors provide
Item 14: CLIENT REFERRALS and OTHER COMPENSATION
A.
non-monetary assistance by making available research that their firms have published or providing
educational pieces for clients. We do not select products as a result of any monetary or
non-monetary assistance. The selection of product that is most appropriate for the client is first and
foremost. RPS’s due diligence of a product does not take into consideration any assistance it may
receive. Although the receipt of products or services is a benefit for you and us, it also presents a
conflict of interest.
RPS attempts to mitigate the conflict of interest by notifying you of the conflict. We inform you that
you are free to consult other financial professionals. We are bound by our Code of Ethics to act in an
ethical manner and our fiduciary responsibility to act in your best interest.
RPS does not directly or indirectly compensate any person or entity that is not a supervised
B.
person of our firm for client referrals.
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Item 15: CUSTODY
For clients that do not have their fees deducted directly from their account(s) and have not provided
RPS with any standing letters of authorization to distribute funds from their account(s), RPS will not
have any custody of client funds or securities. For clients that have their fees deducted directly from
their account(s) or that have provided RPS with discretion as to amount and timing of disbursements
pursuant to a standing letter of authorization to disburse funds from their account(s), RPS will
typically be deemed to have limited custody over such clients’ funds or securities pursuant to the
SEC’s custody rule and subsequent guidance thereto. At no time will RPS accept full custody of
client funds or securities in the capacity of a custodial broker-dealer, and at all times client accounts
will be held by a third-party qualified custodian as described in Item 12, above.
If a client receives account statements from the custodial broker-dealer and portfolio allocation
reports from RPS or a third-party report provider, client is urged to compare such account statements
and reports and advise RPS of any discrepancies between them.
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Item 16: INVESTMENT DISCRETION
You may grant RPS authorization to manage your account on a discretionary basis. You will grant
such authority to RPS by execution of the advisory agreement. You may terminate the discretionary
authorization at any time by giving us written notice.
Additionally, you are advised that:
1. You may set parameters with respect to when account should be rebalanced and set trading
restrictions or limitations; and
2. Your written consent is required to establish any mutual fund, variable annuity, or brokerage
account.
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Item 17: VOTING CLIENT SECURITIES
RPS does not vote your securities. Unless you suppress proxies, securities proxies will be sent
directly to you by the account custodian or transfer agent. You may contact your Advisory
Representative about questions you may have and opinions on how to vote the proxies. However,
the decision to vote and how you vote the proxies is solely up to you.
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RPS will not require you to prepay more than $1,200 and 6 or more months in advance of
Item 18: FINANCIAL INFORMATION
A.
receiving the advisory service; therefore, a balance sheet is not required to be attached.
RPS is financially stable. There is no financial condition that is likely to impair our ability to
B.
meet our contract actual commitment to you or any other client.
Neither RPS nor any of its Advisory Representatives has ever been the subject of a
C.
bankruptcy petition.
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