Overview
- Headquarters
- Carmel, IN
- Average Client Assets
- $3.3 million
- Minimum Account Size
- $2,000,000
- SEC CRD Number
- 109563
Fee Structure
Primary Fee Schedule (FORM ADV PART 2 AND 2B 041326)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | and above | 0.50% |
Minimum Annual Fee: $2,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | Below minimum client size | |
| $5 million | $30,000 | 0.60% |
| $10 million | $55,000 | 0.55% |
| $50 million | $255,000 | 0.51% |
| $100 million | $505,000 | 0.50% |
Clients
- HNW Share of Firm Assets
- 92.17%
- Total Client Accounts
- 1,076
- Discretionary Accounts
- 1,076
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Pooled Investment Vehicles, Investment Advisor Selection
Regulatory Filings
Primary Brochure: FORM ADV PART 2 AND 2B 041326 (2026-04-13)
View Document Text
Item 1: Cover Page
Halter Ferguson Financial, Inc.
13080 Grand Blvd., Suite 130
Carmel, Indiana 46032
317-875-0202
http://www.hffinancial.com
April 13, 2026
This brochure provides information about the qualifications and business practices of Halter Ferguson
Financial, Inc. If you have any questions about the contents of this brochure, please contact us at 317-
875-0202 or info@hffinancial.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.
Halter Ferguson Financial, Inc. is a registered investment adviser. Registration of an investment
adviser does not imply any level of skill or training.
Additional information about Halter Ferguson Financial, Inc. also is available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD
number. Halter Ferguson Financial, Inc.’s CRD number is 109563.
Item 2: Summary of Material Changes
There have been no material changes since the March 26, 2026, Form ADV filed on the IARD system.
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Item 3: Table of Contents
Item 1: Cover Page .................................................................................................. 1
Item 2: Summary of Material Changes .................................................................... 2
Item 3: Table of Contents ........................................................................................ 3
Item 4: Advisory Business ....................................................................................... 4
Item 5: Fees and Compensation .............................................................................. 5
Item 6: Performance-Based Fees and Side-By-Side Management .......................... 6
Item 7: Types of Clients ........................................................................................... 7
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss .................. 7
Item 9: Disciplinary Information ............................................................................. 8
Item 10: Other Financial Industry Activities and Affiliations ................................... 8
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading ............................................................................................... 9
Item 12: Brokerage Practices .................................................................................. 10
Item 13: Review of Accounts ................................................................................... 12
Item 14: Client Referrals and Other Compensation ................................................ 12
Item 15: Custody ..................................................................................................... 13
Item 16: Investment Discretion ............................................................................... 13
Item 17: Voting Client Securities ............................................................................. 13
Item 18: Financial Information ................................................................................ 13
Privacy Policy ........................................................................................................... 13
Form ADV Part 2b for Each Supervised Person ....................................................... 15
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Item 4: Advisory Business
Halter Ferguson Financial, Inc. (“Halter Ferguson Financial”) was founded in Indianapolis, Indiana in
1986. The principal and sole shareholder is Bradford S. Ferguson, CFA.
Halter Ferguson Financial is a fee only financial planning and investment advisory firm that provides
these services to individuals as well as businesses. These services are tailored to the individual needs of
clients. Halter Ferguson Financial provides discretionary portfolio management services. The portfolio
management clients give discretion to Halter Ferguson Financial to act in buying and selling securities,
selection of the custodian, selection and retention of separate account managers, and transaction rates
in managing the client’s account. After developing an investment management policy with the client,
Halter Ferguson Financial receives written authority by the client to buy and sell securities on behalf of
the client within the stated parameters of that policy. Clients may impose in writing restrictions on
investing in certain securities, types of securities or the sale of securities presently owned by the client.
REBELLIONAIRE
For limited, specific clients, we manage concentrated investments with the selective use of options
strategies. We have deemed these clients “REBELLIONAIRES” since they tend to have a more non-
diversified approach of investing in a single asset, small number of assets, or a single asset class. As a
result of this non-diversified approach, these clients typically have a higher risk tolerance and are in a
position to incur significant short-term losses or illiquidity.
Financial planning services are described in the Halter Ferguson Financial, Inc. Financial Planning
Engagement Agreement. This Agreement is provided to you before your first planning meeting and is
also available on request. Halter Ferguson Financial is a fiduciary and is required to act in a client’s best
interest at all times.
We also provide investment advisory services to a private investment fund, LumaSenseye II, a series of
HCAM WY LLC. LumaSenti LLC, an affiliate of Halter Ferguson Financial serves as organizer to the fund.
The fund assets are held at a qualified custodian. The fund offers securities to investors only through
private placements of such securities. Please refer to the fund’s offering documents for information
related to the risks, suitability requirements, investment objectives, fee charges and expenses for the
fund.
Halter Ferguson Financial uses a third-party platform to facilitate management of held away assets,
which are primarily 401(k) accounts, HSAs, and other assets. The platform allows Halter Ferguson
Financial to avoid being considered to have custody of client funds since Halter Ferguson Financial does
not have direct access to client log-in credentials. Halter Ferguson Financial is not affiliated with the
platform in any way and receives no compensation from them for using their platform. A link will be
provided to the client allowing them to connect an account(s) to the platform. Once client account(s) is
connected to the platform, Halter Ferguson Financial regularly reviews the available investment options
in these accounts, monitor them, and rebalance and implement Halter Ferguson Financial’s strategies.
As of December 31, 2025, Halter Ferguson Financial had $704,950,608 of assets under discretionary
management.
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Item 5: Fees and Compensation
Halter Ferguson Financial’s fees are stated in the Investment Management Agreement. The fee for
discretionary portfolio management services is based upon the following fee schedule:
Household Assets
Quarterly Fee
Annualized Fee*
First $1,000,000
0.2500 %
1.00 %
Over $1,000,000
0.1250 %
0.50 %
*Minimum client relationship size is generally $2,000,000, but this amount is negotiable.
This fee includes financial planning services, is assessed in arrears, accrued daily, and billed quarterly
based on the market value of the Household Assets, including cash, on the last day of the previous
quarter as valued by the Custodian. Although we have established the aforementioned fee schedule,
we retain the discretion to negotiate alternative fees or waive the minimum fee/minimum client
relationship size on a client-by-client basis. Client facts, circumstances, and needs are considered in
determining the fee schedule. These include the complexity of the client, assets to be placed under
management, anticipated future additional assets; related accounts; portfolio style, account
composition, reports, among other factors. The specific annual fee schedule is identified in the contract
between the adviser and each client. We may group certain related client accounts for the purposes of
achieving the minimum client relationship requirements to determine the Household Assets.
REBELLIONAIRE
For limited, specific clients, deemed “REBELLIONAIRES”, we manage concentrated investments with the
selective use of options strategies. The fee for these services is based upon the following fee schedule:
Household Assets For
Tier
Quarterly Fee Applicable to
Household Assets in Tier
Annualized Fee*
Applicable to
Household Assets in
Tier
First $5,000,000
0.2500 %
1.00 %
Over $5,000,000
0.1250 %
0.50 %
*Minimum client relationship size of $2,000,000.
This fee includes financial planning services, is assessed in arrears, accrued daily, and billed quarterly
based on the market value of the Household Assets, including cash, on the last day of the previous
quarter as valued by the Custodian. Although we have established the aforementioned fee schedule,
we retain the discretion to negotiate alternative fees or waive the minimum client relationship size on a
client-by-client basis.
Clients may pay Halter Ferguson Financial fees directly. Fees may also be directly deducted from the
client’s custodian account. Halter Ferguson Financial does not and will not have physical custody of
client funds or securities.
In addition to the fee paid directly to Halter Ferguson Financial, the client will pay fees for custodial
services, and for brokerage and other costs associated with client account transactions. Custodial fees
vary by the size of the account and account type. Brokerage and other transactions costs also vary
based on the level of account activity. Halter Ferguson Financial may recommend that clients establish
brokerage accounts with Charles Schwab & Co., Inc. (“Schwab”) or with Fidelity Institutional Wealth
Services (“Fidelity”) to maintain custody of clients’ assets and to effect trades for their accounts.
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Schwab and Fidelity are independent and unaffiliated registered broker-dealers and members of FINRA
and SIPC. For Halter Ferguson Financial client accounts maintained in their custody, Schwab and Fidelity
generally do not charge separately for custody but are compensated by account holders through
transaction-related fees for securities trades that are executed through Schwab or Fidelity or that settle
into their accounts.
Clients may also incur other fees and costs. If client assets are invested in mutual funds, the client will
pay indirectly to the mutual fund company management and other fees for those funds (the mutual
fund fees are described in the funds’ prospectuses). If a separate account manager is retained for a
client’s account, the client will also be responsible for paying directly to any separate account manager
(and the custodian of that account) any separate account fees required for that account. Separate
account fees vary by the size of the account and type of account, and will be disclosed to the client. The
services may cost the client more or less than purchasing such services separately depending upon
account fees, trading costs, and/or active management fees.
Clients will incur brokerage and other transaction costs. Please see Item 12 for more information about
Halter Ferguson Financial’s brokerage practices.
SELECTION AND MONITORING OF THIRD-PARTY MONEY MANAGERS
We also offer advisory management services to our clients through our Selection and Monitoring
of Third-Party Money Managers programs (hereinafter, "Programs").
We provide the client with an asset allocation strategy developed through personal discussions in which
goals and objectives based on the client's particular circumstances are established. Based on the client's
individual circumstances and needs we will then perform management searches of various unaffiliated
registered investment advisers to identify which registered investment adviser's portfolio management
style is appropriate for that client. Factors considered in making this determination include account size,
risk tolerance, the opinion of each client and the investment philosophy of the selected registered
investment adviser. Clients should refer to the selected registered investment adviser's Firm Brochure or
other disclosure document for a full description of the services offered. We are available to meet with
clients on a regular basis, or as determined by the client, to review the account.
We monitor the performance of the selected registered investment adviser(s). If we determine that a
particular selected registered investment adviser(s) is not providing sufficient management services to
the client, we may suggest that the client contract with a different registered investment adviser and/or
program sponsor. Under this scenario, we assist the client in selecting a new registered investment
adviser and/or program. However, any move to a new registered investment adviser and/or program is
solely at the discretion of the client.
Item 6: Performance-Based Fees and Side-By-Side Management
We have entered into a performance fee arrangement with the private fund, LumaSenseye II, a series of
HCAM WY LLC. The receipt of performance-based fees creates a conflict of interest. Performance-based
fee arrangements create an incentive for us to recommend investments which may be riskier or more
speculative than those which would be recommended under a different fee arrangement. In order to
reduce potential conflicts of interest, we do not show preferential treatment to accounts under a
performance-based fee arrangement. We have procedures designed and implemented to treat all
clients fairly over time, and to prevent this potential conflict from influencing our selection of
investments for accounts with performance-based fee arrangements or the allocation of investment
opportunities among clients.
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Item 7: Types of Clients
Halter Ferguson Financial provides financial planning and investment advice to individuals, families,
small businesses, trusts, charitable organizations and profit sharing plans. Although we do not have a
minimum account size, our minimum client relationship is generally $2,000,000. There is no
requirement to maintain a minimum account balance, but the minimum portfolio management fee is
$500 dollars per quarter. All fees and minimums are negotiable depending on size, number and type of
accounts, and for family members.
Clients eligible to enroll in the Program include individuals, IRAs, and revocable living trusts. Clients that
are organizations (such as corporations and partnerships) or government entities, and clients that are
subject to the Employee Retirement Income Security Act of 1974, are not eligible for the Program. The
minimum investment required to open an account in the Program is $5,000. The minimum account
balance to enroll in the tax-loss harvesting feature is $50,000.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Fundamental analysis is the primary method used to select investments. Halter Ferguson Financial
follows the market on a regular basis and does a significant amount of reading and research to form an
overall view of the market. Research resources include in-house research and various independent
analysis reports and reporting services. Analysis also includes interpretation of indicators that are
related to market sentiment (bullishness, bearishness, money flows). Halter Ferguson Financial uses
these views to aid in determining an initial asset allocation. Market expectations are then merged with
client objectives and risk tolerance to create a strategic asset allocation.
After developing an Investment Policy Statement with the client, the Advisor is given written authority
(Investment Management Agreement) by the client to buy and sell securities on behalf of the client
within the stated parameters of the Investment Policy Statement. The Investment Policy Statement can
be changed to reflect changes in the client’s objectives and risk tolerance. Typically, diversification of
investments based on the client’s objectives will be part of the recommendations. This type of investing
utilizes themes to invest for the intermediate to long term. Halter Ferguson Financial invests client
dollars and overweight’s areas that it believes have favorable risk-return characteristics. Halter
Ferguson Financial considers all of client’s investments with the goal that the investments work together
to either enhance return and/or reduce risk.
Investment recommendations may include mutual funds (including commodity, arbitrage and bond-
backed derivative mutual funds), stocks, bonds, notes, bills, separate account managers, publicly traded
REITs, options, annuities, certificates of deposit, cash or money market accounts.
As part of our investment strategy, we may recommend allocating portions of a client’s assets to mutual
funds, publicly traded REITs, or separate accounts managed by third party investment managers. Those
other independent managers will have total investment discretion over the assets allocated to them.
We annually conduct due diligence and monitor the performance on an ongoing basis of the investment
vehicles and separate accounts managed by other managers. Nonetheless, they may conduct business
with different custodians, banks, brokers, dealers and counterparties than those we utilize. Moreover,
we have no direct ability to ensure that those other managers act in accordance with the stated
investment policies or objectives of those funds or accounts, or otherwise act in conformity with
applicable contractual, legal, regulatory or other standards and restrictions.
For limited, specific clients, we manage concentrated investments with the selective use of options
strategies. These clients tend to have a more non-diversified approach of investing in a single asset,
small number of assets, or a single asset class. Investing in a single asset or a small number of assets can
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be risky, as the performance of those assets can have a significant impact on the overall portfolio return.
If a client’s portfolio is heavily weighted towards one particular asset or asset class, then the client’s
returns may be highly dependent on the performance of that asset or asset class.
We may use options as an investment strategy. An option is a contract that gives the buyer the right, but
not the obligation, to buy or sell an asset (such as a share of stock) at a specific price on or before a
certain date. An option, just like a stock or bond, is a security which may lose value. An option is also a
derivative, because it derives its value from an underlying asset.
The two types of options are calls and puts:
• A call gives a purchaser the right to buy an asset at a certain price within a specific period of time.
We may buy a call if we believe the stock will increase in value before the option expires.
• A put gives a purchaser the right to sell an asset at a certain price within a specific period of time.
We may buy a put if we believe that the price of the stock will fall before the option expires.
We may use options or funds with similar objectives to speculate on the possibility of a price swing. We
may also use options to "hedge" a purchase of the underlying security; in other words, we may use an
option purchase to limit the potential upside and downside of a security we have purchased for a client
portfolio.
We more commonly use "covered calls", in which we sell an option on a security a client owns. In this
strategy, the client receives a premium for making the option available, and the person purchasing the
option has the right to buy the security at an agreed-upon price and date.
In certain situations, we may recommend investments in selected private placements, including private
funds advised on by us. These types of investments present unique risks due to the lack of liquidity.
These types of investments also have varied and unique fee structures of their own. Due to the unique
and complex nature of these investments, clients will receive a separate disclosure prior to any
investments being made.
Investing in securities involves risk and clients bear the risk of loss on their investments. We ask that
you work with us to help us understand your tolerance for risk.
Item 9: Disciplinary Information
Not applicable.
Item 10: Other Financial Industry Activities and Affiliations
Halter Ferguson Financial is an equal owner of LumaSenti LLC. LumaSenti LLC serves as organizer to
LumaSenseye II, a series of HCAM WY LLC, a private investment fund. LumaSenti LLC has designated
Halter Ferguson Financial as investment adviser to the fund. As mentioned in Item 6 Performance-Based
Fees and Side-By-Side Management, Halter Ferguson Financial will earn performance-based fees once a
pre-determined hurdle rate is reached. The firm, its affiliates, and its employees are prohibited from
taking commissions or other compensation from the sponsors of investments in the fund.
Halter Ferguson Financial typically does not charge management fees within any private fund vehicle for
advisory clients. Management/advisory fees are typically charged on an AUM basis or a fixed fee basis at
the firm level. There are no instances where Halter Ferguson Financial charges its clients a fee on both
an AUM basis at the firm level and within the private fund (no double charging). Clients who invest in
the private fund pay their portion of standard fund expenses, including operation fees, and in some
instances, performance fees.
The fund is not required to register as an investment company under the Investment Company Act of
1940 in reliance upon one or more exemptions available to funds whose securities are not publicly
8
offered. Halter Ferguson Financial manages the fund on a discretionary basis in accordance with the
terms and conditions of the fund’s offering and organizational documents.
Matthew Smith, an employee of Halter Ferguson Financial, is a minority owner of Good Soil Investment
Management, LLC. As an exempt reporting adviser, Good Soil Investment Management, LLC serves as
general partner and advises on operations. Good Soil Investment Management, LLC and Halter Ferguson
Financial are not affiliated entities. Advisory clients of Halter Ferguson Financial are not solicited for
investments in any of the partnerships for which Good Soil Investment Management, LLC serves as
general partner or for which Good Soil Investment Management, LLC provides investment advice.
Furthermore, Halter Ferguson Financial does not provide investment advice to Good Soil Investment
Management, LLC or any of the private funds for which Good Soil Investment Management, LLC serves
as general partner or provides investment advice.
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
The Halter Ferguson Financial Code of Ethics is based on the principle that Halter Ferguson Financial
owes a fiduciary duty to its clients. As a fiduciary Halter Ferguson Financial will serve its clients’ best
interests and place those interests ahead of those of Halter Ferguson Financial. Halter Ferguson
Financials Code of Ethics is available to any client or prospective client upon request.
Under the Code of Ethics, employees are permitted to invest in securities and other investment
products for their own accounts, but may not use their knowledge of clients’ portfolio transactions to
benefit themselves.
We do not impose a set limit on the amount of trading employees may conduct for their own accounts,
but we require employees to refrain from excessive trading.
Our Code of Ethics requires employees to disclose all personal investments upon hire and at least
annually thereafter, report all personal securities transactions at least quarterly, disclose all personal
investment accounts, and maintain their personal investment accounts with designated broker-dealer
firms. Exceptions may be made for accounts for which the employee does not maintain investment
control or participate in the investment decisions. Employees generally must arrange for their brokers
to send us duplicate trade confirmations and account statements for their transactions, and must
separately report on a quarterly basis any transaction for which a duplicate confirmation was not sent,
or which does not appear on an account statement.
Employees’ personal securities transactions generally must be approved in advance, subject to certain
limited exceptions. Employees are prohibited from acquiring any securities in an initial public offering,
while securities may be acquired in a secondary public offering with prior approval. Employees must
obtain prior approval before acquiring any security in a private placement or investing in a private
investment fund.
Our Code of Ethics requires employees to obtain prior approval to engage in certain outside business
activities (such as serving as a director of a private, public or non-profit company). The Code of Ethics
also prohibits employees from accepting gifts of material value from clients, vendors, service providers,
and counterparties. Halter Ferguson Financial related persons do not buy or sell securities from clients.
Halter Ferguson Financial related persons can purchase or sell for their own account similar or different
open-end funds as those purchased for, or recommended to, clients. Because these funds generally are
broadly diversified and transact purchases and redemptions at net asset values determined after orders
are received, Halter Ferguson Financial does not believe that a transaction by related persons presents
any material conflict with client account.
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Item 12: Brokerage Practices
The Custodian and Brokers We Use
Halter Ferguson Financial does not maintain physical custody of your assets that we manage, although
are deemed to have custody of your assets if you give us authority to withdraw assets from your
account. Your assets must be maintained in an account at the “qualified custodian,” generally a broker-
dealer or bank. We typically recommend that our clients use Charles Schwab & Co., Inc. (“Schwab”) or
Fidelity Institutional Wealth Services (“Fidelity”) as the qualified custodian. Schwab and Fidelity are
independent and unaffiliated registered broker-dealers and members of FINRA and SIPC. Schwab and
Fidelity will hold your assets in a brokerage account and buy and sell securities when we or you instruct
them to.
While we recommend that you use Schwab or Fidelity as custodian/broker, you will decide whether to
do so and will open your account with Schwab or Fidelity by entering into an account agreement directly
with them. We do not open the account for you, although we may assist you in doing so. Even though
your account is maintained at Schwab or Fidelity, we can still use other brokers to execute trades for
your account as described below (see “Your Brokerage and Custody Costs”).
How We Select Brokers/Custodians
We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms
that are, overall, most advantageous when compared to other available providers and their services.
We consider a wide range of factors, including, among others:
• Combination of transaction execution services and asset custody services (generally without a
separate fee for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for your account)
• Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds
[ETFs], etc.)
• Availability of investment research and tools that assist us in making investment decisions
• Quality of services
• Competitiveness of the price of those services (commission rates, margin interest rates, other
fees, etc.) and willingness to negotiate the prices
• Reputation, financial strength, and stability
• Prior service to us and our other clients
• Availability of other products and services that benefit us, as discussed below (see “Products and
Services Available to Us From Schwab and Fidelity”)
Your Brokerage and Custody Costs
For our clients’ accounts that Schwab or Fidelity maintain, Schwab and Fidelity generally do not charge
you separately for custody services but are compensated by charging you commissions or other fees on
trades that they execute or that settle into their accounts. For some accounts, Schwab may charge you a
percentage of the dollar amount of assets in the account in lieu of commissions. Schwab’s commission
rates and asset-based fees applicable to our client accounts were negotiated based on the condition
that our clients collectively maintain a total of at least $10 million of their assets in accounts at Schwab.
This commitment benefits you because the overall commission rates or asset-based fees you pay are
lower than they would be otherwise.
In addition to transaction-related fees or asset-based fees, Schwab or Fidelity charge you a flat dollar
amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different
broker-dealer but where the securities bought or the funds from the securities sold are deposited
10
(settled) into your Schwab or Fidelity account. These fees are in addition to the transaction-related fees
or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your
trading costs, we have Schwab or Fidelity execute most trades for your account. We have determined
that having Schwab or Fidelity execute most trades is consistent with our duty to seek “best execution”
of your trades. Best execution means the most favorable terms for a transaction based on all relevant
factors, including those listed above (see “How We Select Brokers/Custodians”).
Products and Services Available to Us From Schwab and Fidelity
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us.
Together with Fidelity, they provide us and our clients with access to their institutional brokerage—
trading, custody, reporting, and related services—many of which are not typically available to Schwab or
Fidelity retail customers. Schwab and Fidelity also make available various support services. Some of
those services help us manage or administer our clients’ accounts; while others help us manage and
grow our business. Schwab’s and Fidelity’s support services generally are available on an unsolicited
basis (we don’t have to request them) and at no charge to us as long as our clients collectively maintain
a total of at least $10 million of their assets in accounts at Schwab or Fidelity. If our clients collectively
have less than $10 million in assets at Schwab or Fidelity, they may charge us quarterly service fees of
$1,200. Following is a more detailed description of Schwab’s and Fidelity’s support services:
Services That Benefit You
Schwab’s and Fidelity’s brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through Schwab and Fidelity include some to which we might not otherwise have access or that would
require a significantly higher minimum initial investment by our clients. Schwab’s and Fidelity’s services
described in this paragraph generally benefit you and your account.
Services That May Not Directly Benefit You
Schwab and Fidelity also make available to us other products and services that benefit us but may not
directly benefit you or your account. These products and services assist us in managing and
administering our clients’ accounts. They include investment research, both Schwab’s and Fidelity’s own
and that of third parties. We may use this research to service all or a substantial number of our clients’
accounts, including accounts not maintained at Schwab or Fidelity. In addition to investment research,
Schwab and Fidelity also make available software and other technology that:
• Provide access to client account data (such as duplicate trade confirmations and account
statements)
• Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
• Provide pricing and other market data
• Facilitate payment of our fees from our clients’ accounts
• Assist with back-office functions, recordkeeping, and client reporting
Services That Generally Benefit Only Us
Schwab and Fidelity also offer other services intended to help us manage and further develop our
business enterprise. These services include:
• Educational conferences and events
• Consulting on technology, compliance, legal, and business needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance providers
Schwab and Fidelity may provide some of these services themselves. In other cases, they will arrange for
third-party vendors to provide the services to us. Schwab and Fidelity may also discount or waive their
fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us
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with other benefits, such as occasional business entertainment of our personnel.
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not have to produce or
purchase them. We don’t have to pay for Schwab’s services so long as our clients collectively keep a
total of at least $10 million of their assets in accounts at Schwab. Beyond that, these services are not
contingent upon us committing any specific amount of business to Schwab in trading transaction-related
fees or assets in custody. The $10 million minimum may give us an incentive to recommend that you
maintain your account with Schwab, based on our interest in receiving Schwab’s services that benefit
our business rather than based on your interest in receiving the best value in custody services and the
most favorable execution of your transactions. This is a conflict of interest. We believe, however, that
our selection of Schwab as our primary custodian and broker is in the best interest of our clients. Our
selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How We
Select Brokers/Custodians”) and not Schwab’s services that benefit only us. We have in excess of $100
million in client assets under management, and we do not believe that recommending our clients to
collectively maintain at least $10 million of those assets at Schwab in order to avoid paying Schwab
quarterly service fees presents a material conflict of interest.
If we make a trade error that results in a loss to a client, we will make the client whole. If we make a
trade error that results in a gain to a client and the gain cannot be attributable to a particular client,
Schwab, and not us, keeps the gain. In that case, if the gain is more than $100, Schwab will donate the
gain to charity. If the gain is less than $100, Schwab will keep the gain to minimize and offset its
administrative time and expense.
We also use other custodians as requested by the client, which could result in the client paying more in
custodial fees and transaction charges. For example, a client that trades at a custodian other than
Schwab or Fidelity may not be able to participate in an aggregated trade.
Item 13: Review of Accounts
Managed Accounts – All client accounts are reviewed at least quarterly, and a written report is issued to
all clients about 10 days following the end of a quarter. Clients may elect in writing to receive their
reports electronically. In addition to quarterly review, client accounts are reviewed and adjusted by the
investment advisors as economic, market conditions and fund portfolio managers change. Client
meetings and phone consultations to review the client’s account activity are included in the service for
investment management clients. At least an annual review meeting or phone conference is
recommended but not required. Principal Bradford S. Ferguson, CFA is accountable for providing these
services.
Item 14: Client Referrals and Other Compensation
Halter Ferguson Financial does not directly or indirectly compensate any person for client referrals.
Halter Ferguson Financial is a fee only firm and is not compensated by any person or firm who provides
advisory services to our clients.
We receive an economic benefit from Schwab and Fidelity in the form of the support products and
services they make available to us. These products and services, how they benefit us, and the related
conflicts of interest are described above under Item 12 Brokerage Practices. The availability to us of
Schwab’s and Fidelity’s products and services is not based on us giving particular investment advice,
such as buying particular securities for our clients.
12
Item 15: Custody
Halter Ferguson Financial does not have physical custody of client funds or securities. If there is any
activity in a client account, clients receive monthly statements from the account custodian. If there is no
activity in a client account, clients receive quarterly statements from the account custodian. Clients
should carefully review those statements. Halter Ferguson Financial sends quarterly statements about
10 days following the end of a quarter. In addition to showing client holdings and value of the client
account at the end of the quarter, the report contains the billing for the management fee. Clients
should compare the account statements they receive from Halter Ferguson Financial with those they
receive from the custodian. The account custodian does not calculate nor verify the accuracy of the
advisory fee calculation. Clients may have standing letters of authorization on their accounts. The Firm
has reviewed those relationships and determined that they meet the IAA no action letter seven
conditions and do not trigger the surprise custody audit.
We are considered to have custody of client assets due to the relationship with the private fund. The
fund assets are held at a qualified custodian.
Item 16: Investment Discretion
Clients who engage Halter Ferguson Financial for portfolio management services enter into an
Investment Management Agreement with Halter Ferguson Financial. This agreement gives Halter
Ferguson Financial discretion over their accounts. Discretion means Halter Ferguson Financial can buy
and sell securities, and terminate separate accounts, without consulting with the client. Clients may
impose in writing restrictions on investing in certain securities, types of securities or the sale of
securities presently owned by the client. This should be done in writing at the time the client signs the
Investment Policy Statement. The Investment Management Agreement can be cancelled by the client or
by Halter Ferguson Financial by giving 30 days written notice.
Item 17: Voting Client Securities
As provided in Schwab’s or Fidelity’s account application the client does not appoint the Halter Ferguson
Financial voting authority. Halter Ferguson Financial does not vote proxies for the client. The client is
responsible for all issuer and issuer-related communications (proxies, tender offers, proposed mergers,
rights offerings, exchange offers and warrants, among other things) that may require a voting decision
or other action regarding investments held in your account. The custodian will send all issuer and issuer-
related communications directly to the client. The client will be responsible for providing the custodian
any applicable instructions or directions on those items. If requested by the client, Halter Ferguson
Financial will provide advice on those actions that directly affect the client’s holdings, but will not
provide advice on proxy voting.
Item 18: Financial Information
Halter Ferguson does not require or solicit prepayment of more than $1,200 in fees six months or more
in advance. Halter Ferguson does not have any adverse financial information to disclose.
Privacy Notice To Our Clients.
We have adopted this policy with recognition that protecting the privacy and security of the personal
information we obtain about our customers is an important responsibility. We also know that the
customer expects us to service their accounts in an accurate and efficient manner. To do so, we must
collect and maintain certain personal information about our customers. We want the customer to know
what information we collect and how we use and safeguard that information.
What Information We Collect
We collect certain nonpublic personal identifying information about our customers (such as name,
address, social security number, etc.) from information that the customer provides on applications or
13
other forms as well as communications (electronic, telephone, written, or in person) with the customer
or authorized representatives (such as attorneys, accountants, etc.). We also collect information about
brokerage accounts and transactions (such as purchases, sales, account balances, inquiries, etc.).
What Information We Disclose
We do not disclose the nonpublic personal information we collect about our customers to anyone
except: (i) in furtherance of our business relationship and then only to those persons necessary to effect
the transactions and provide the services that the customer authorizes (such as broker-dealers,
custodians, independent managers, etc.); (ii) persons assessing our compliance with industry standards
(e.g. professional licensing authorities, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as
otherwise provided by law.
We are permitted by law to disclose the nonpublic personal information about our customers to
governmental agencies and other third parties in certain circumstances (such as third parties that
perform administrative or marketing services on our behalf or for joint marketing programs). These
third parties are prohibited to use or share the information for any purpose. If the customer decides at
some point to either terminate our services or become an inactive customer, we will continue to adhere
to our privacy policy, as may be amended from time to time.
Security of Customer Information
We restrict access to customer nonpublic personal information to those employees who need to know
that information to service the accounts. We maintain physical, electronic, and procedural safeguards
that comply with applicable federal or state standards to protect customer personal information.
Changes To Our Privacy Policy Or Relationship With The Customer
Our policy about obtaining and disclosing information may change from time to time. We will provide
the customer notice of any material change to this policy before we implement the change.
If your personal information with us becomes inaccurate, or if you need to make a change to that
information, please contact us at the number shown below so we can update our records.
14
Item 1: Cover Page
Bradford S. Ferguson
Halter Ferguson Financial, Inc.
13080 Grand Blvd., Suite 130
Carmel, Indiana 46032
317-875-0202
http://www.hffinancial.com
CRD number: 5062898
April 13, 2026
This brochure supplement provides information about Bradford S. Ferguson that supplements the
Halter Ferguson Financial brochure. You should have received a copy of that brochure. Please contact
Matthew Smith, Chief Compliance Officer if you did not receive Halter Ferguson Financial’s brochure
or if you have questions about the contents of this supplement
Additional information about Bradford S. Ferguson is available on the SEC’s website at
www.adviserinfo.sec.gov.
15
Item 2: Education and Background
Bradford S. Ferguson, CFA
Year of Birth: 1976
EDUCATION
Northwestern University, Evanston, IL, 1999, B.A. Statistics & Economics.
CFA Institute, Charlottesville, NC, obtained Chartered Financial Analyst Charter 2006.
BUSINESS BACKGROUND
Halter Ferguson Financial, April 2005 to Present.
The Chartered Financial Analyst (CFA) charter is a globally respected, graduate-level investment
credential established in 1962 and awarded by CFA Institute — the largest global association of
investment professionals. There are currently more than 90,000 CFA charterholders working in 135
countries. To earn the CFA charter, candidates must: 1) pass three sequential, six-hour examinations; 2)
have at least four years of qualified professional investment experience; 3) join CFA Institute as
members; and 4) commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code
of Ethics and Standards of Professional Conduct.
High Ethical Standards
The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active
professional conduct program, require CFA charterholders to:
• Place their clients’ interests ahead of their own
• Maintain independence and objectivity
• Act with integrity
• Maintain and improve their professional competence
• Disclose conflicts of interest and legal matters
Global Recognition
Passing the three CFA exams is a difficult feat that requires extensive study (successful candidates report
spending an average of 300 hours of study per level). Earning the CFA charter demonstrates mastery of
many of the advanced skills needed for investment analysis and decision making in today’s quickly
evolving global financial industry. As a result, employers and clients are increasingly seeking CFA
charterholders—often making the charter a prerequisite for employment. Additionally, regulatory
bodies in 19 countries recognize the CFA charter as a proxy for meeting certain licensing requirements,
and more than 125 colleges and universities around the world have incorporated a majority of the CFA
Program curriculum into their own finance courses.
Comprehensive and Current Knowledge
The CFA Program curriculum provides a comprehensive framework of knowledge for investment
decision making and is firmly grounded in the knowledge and skills used every day in the investment
profession. The three levels of the CFA Program test a proficiency with a wide range of fundamental and
advanced investment topics, including ethical and professional standards, fixed-income and equity
analysis, alternative and derivative investments, economics, financial reporting standards, portfolio
management, and wealth planning.
The CFA Program curriculum is updated every year by experts from around the world to ensure that
candidates learn the most relevant and practical new tools, ideas, and investment and wealth
management skills to reflect the dynamic and complex nature of the profession. To learn more about
the CFA charter, visit www.cfainstitute.org.
16
Item 3: Disciplinary Information
Not applicable.
Item 4: Other Business Activities
Not applicable.
Item 5: Additional Compensation
Not applicable.
Item 6: Supervision
Only the firm professionals Bradford S. Ferguson, CFA, Tiffany White, CFP®, Matthew Smith, Benjamin
Weber, Isaac Yops, and Henry Dierkes provide advice to clients. Matthew Smith, Chief Compliance
Officer, is responsible for all supervision. His phone number is 317-875-0202. As part of this role, Mr.
Matthew Smith does quarterly spot checks of financial plans and investment reviews being presented to
each client. Matthew Smith reviews all written client performance materials and newsletters prior to
use. On a weekly basis, the investment team meets to discuss investment strategies and market
conditions.
17
Item 1: Cover Page
Tiffany White
Halter Ferguson Financial, Inc.
13080 Grand Blvd., Suite 130
Carmel, Indiana 46032
317-875-0202
http://www.hffinancial.com
CRD number: 6435426
April 13, 2026
This brochure supplement provides information about Tiffany White that supplements the Halter
Ferguson Financial brochure. You should have received a copy of that brochure. Please contact
Matthew Smith, Chief Compliance Officer if you did not receive Halter Ferguson Financial’s brochure
or if you have questions about the contents of this supplement
Additional information about Tiffany White is available on the SEC’s website at
www.adviserinfo.sec.gov.
18
Item 2: Education and Background
Tiffany White, CFP®
Year of Birth: 1981
EDUCATION
DePauw University, Greencastle, IN 2003, B.A. Economics.
The American College of Financial Services, Bryn Mawr, PA 2010, CFP® Certification Curriculum.
CFP® Certification earned 2014.
BUSINESS BACKGROUND
Halter Ferguson Financial, May 2007 to Present, Financial Planner
In order to achieve and maintain certification, CFP® professionals must: 1) pass the comprehensive
CFP® Certification Examination, 2) pass the CFP Board's Fitness Standards for Candidates and
Registrants, 3) agree to abide by CFP Board's Code of Ethics and Professional Responsibility and Rules of
Conduct which put clients' interests first, 4) comply with the Financial Planning Practice Standards which
spell out what clients should be able to reasonably expect from the financial planning engagement, and
5) complete 30 hours of continuing education (including 2 hours of approved Ethics CE) every two
years. - See more at: http://www.cfp.net/become-a-cfp-professional/cfp-certification-
requirements#sthash.qwXJz3yF.dpuf.
Item 3: Disciplinary Information
Not applicable.
Item 4: Other Business Activities
Not applicable.
Item 5: Additional Compensation
None.
Item 6: Supervision
Only the firm professionals Bradford S. Ferguson, CFA, Tiffany White, CFP®, Matthew Smith, Benjamin
Weber, Isaac Yops, and Henry Dierkes provide advice to clients. Matthew Smith, Chief Compliance
Officer, is responsible for all supervision. His phone number is 317-875-0202. As part of this role, Mr.
Matthew Smith does quarterly spot checks of financial plans and investment reviews being presented to
each client. Matthew Smith reviews all written client performance materials and newsletters prior to
use. On a weekly basis, the investment team meets to discuss investment strategies and market
conditions.
19
Item 1: Cover Page
Matthew Smith
Halter Ferguson Financial, Inc.
13080 Grand Blvd., Suite 130
Carmel, Indiana 46032
317-875-0202
http://www.hffinancial.com
CRD number: 5922356
April 13, 2026
This brochure supplement provides information about Matthew Smith that supplements the Halter
Ferguson Financial brochure. You should have received a copy of that brochure. Please contact
Matthew Smith, Chief Compliance Officer if you did not receive Halter Ferguson Financial’s brochure
or if you have questions about the contents of this supplement.
Additional information about Matthew Smith is available on the SEC’s website at
www.adviserinfo.sec.gov.
20
Item 2: Education and Background
Matthew Smith
Year of Birth: 1986
EDUCATION
Michigan State University, East Lansing, MI, B.A. East Asian Languages and Culture, 2009
Michigan State University, East Lansing, MI, B.A. Finance, 2009
University of Michigan, Ann Arbor, MI, Master of Business Education, Ross School of Business, 2018
Series 65
BUSINESS BACKGROUND
Halter Ferguson Financial, May 2023 to Present, VP of Equity Analysis
Good Soil Investment Management, LLC, May 2021 to April, 2023, Manager
CMS Energy Corporation, April 2013 to May 2021, Senior Financial Analyst, Principal Financial Analyst,
and Asset Manager
Item 3: Disciplinary Information
Not applicable.
Item 4: Other Business Activities
Matthew Smith is a minority owner of Good Soil Investment Management, LLC. As an exempt reporting
adviser, Good Soil Investment Management, LLC serves as general partner and advises on operations.
Good Soil Investment Management, LLC and Halter Ferguson Financial are not affiliated entities.
Advisory clients of Halter Ferguson Financial are not solicited for investments in any of the partnerships
for which Good Soil Investment Management, LLC serves as general partner or for which Good Soil
Investment Management, LLC provides investment advice. Furthermore, Halter Ferguson Financial does
not provide investment advice to Good Soil Investment Management, LLC or any of the private funds for
which Good Soil Investment Management, LLC serves as general partner or provides investment advice.
Item 5: Additional Compensation
None.
Item 6: Supervision
Only the firm professionals Bradford S. Ferguson, CFA, Tiffany White, CFP®, Matthew Smith, Benjamin
Weber, Isaac Yops, and Henry Dierkes provide advice to clients. Matthew Smith, Chief Compliance
Officer, is responsible for all supervision. His phone number is 317-875-0202. As part of this role, Mr.
Matthew Smith does quarterly spot checks of financial plans and investment reviews being presented to
each client. Matthew Smith reviews all written client performance materials and newsletters prior to
use. On a weekly basis, the investment team meets to discuss investment strategies and market
conditions.
21
Item 1: Cover Page
Benjamin Weber
Halter Ferguson Financial, Inc.
13080 Grand Blvd., Suite 130
Carmel, Indiana 46032
317-875-0202
http://www.hffinancial.com
CRD number: 6305137
April 13, 2026
This brochure supplement provides information about Benjamin Weber that supplements the Halter
Ferguson Financial brochure. You should have received a copy of that brochure. Please contact
Matthew Smith, Chief Compliance Officer if you did not receive Halter Ferguson Financial’s brochure
or if you have questions about the contents of this supplement.
Additional information about Benjamin Weber is available on the SEC’s website at
www.adviserinfo.sec.gov.
22
Item 2: Education and Background
Benjamin Weber
Year of Birth: 1994
EDUCATION
Indiana State University, Terre Haute, IN, B.S. Finance and Financial Services, 2017
Series 65
BUSINESS BACKGROUND
Halter Ferguson Financial, November 2020 to Present, Investment Adviser Representative
Protect Your Home, July 2020 to November 2020, Sales Agent
Unemployed, March 2020 to July 2020
Uber Technologies Inc., September 2019 to March 2020
Lyft, Inc., September 2019 to March 2020
Item 3: Disciplinary Information
Not applicable.
Item 4: Other Business Activities
Not applicable.
Item 5: Additional Compensation
None.
Item 6: Supervision
Only the firm professionals Bradford S. Ferguson, CFA, Tiffany White, CFP®, Matthew Smith, Benjamin
Weber, Isaac Yops, and Henry Dierkes provide advice to clients. Matthew Smith, Chief Compliance
Officer, is responsible for all supervision. His phone number is 317-875-0202. As part of this role, Mr.
Matthew Smith does quarterly spot checks of financial plans and investment reviews being presented to
each client. Matthew Smith reviews all written client performance materials and newsletters prior to
use. On a weekly basis, the investment team meets to discuss investment strategies and market
conditions.
23
Item 1: Cover Page
Isaac Yops
Halter Ferguson Financial, Inc.
13080 Grand Blvd., Suite 130
Carmel, Indiana 46032
317-875-0202
http://www.hffinancial.com
CRD number: 7833320
April 13, 2026
This brochure supplement provides information about Isaac Yops that supplements the Halter
Ferguson Financial brochure. You should have received a copy of that brochure. Please contact
Matthew Smith, Chief Compliance Officer if you did not receive Halter Ferguson Financial’s brochure
or if you have questions about the contents of this supplement.
Additional information about Isaac Yops is available on the SEC’s website at www.adviserinfo.sec.gov.
24
Item 2: Education and Background
Isaac Yops
Year of Birth: 2001
EDUCATION
Taylor University, Upland, IN, B.S. Finance, May 2023
Series 65
BUSINESS BACKGROUND
Halter Ferguson Financial, June 2023 to Present, Client Service & Investment Management Specialist
Grant County School District, September 2022 to May 2023, Tutor
Taylor University, August 2020 to May 2023, Dorm Front Desk
Item 3: Disciplinary Information
Not applicable.
Item 4: Other Business Activities
Not applicable.
Item 5: Additional Compensation
None.
Item 6: Supervision
Only the firm professionals Bradford S. Ferguson, CFA, Tiffany White, CFP®, Matthew Smith, Benjamin
Weber, Isaac Yops, and Henry Dierkes provide advice to clients. Matthew Smith, Chief Compliance
Officer, is responsible for all supervision. His phone number is 317-875-0202. As part of this role, Mr.
Matthew Smith does quarterly spot checks of financial plans and investment reviews being presented to
each client. Matthew Smith reviews all written client performance materials and newsletters prior to
use. On a weekly basis, the investment team meets to discuss investment strategies and market
conditions.
25
Item 1: Cover Page
Henry Dierkes
Halter Ferguson Financial, Inc.
13080 Grand Blvd., Suite 130
Carmel, Indiana 46032
317-875-0202
http://www.hffinancial.com
CRD number: 8247111
April 13, 2026
This brochure supplement provides information about Henry Dierkes that supplements the Halter
Ferguson Financial brochure. You should have received a copy of that brochure. Please contact
Matthew Smith, Chief Compliance Officer if you did not receive Halter Ferguson Financial’s brochure
or if you have questions about the contents of this supplement.
Additional information about Henry Dierkes is available on the SEC’s website at
www.adviserinfo.sec.gov.
26
Item 2: Education and Background
Henry Dierkes
Year of Birth: 2003
EDUCATION
Concordia University Wisconsin, Mequon, WI, B.S. Finance, December 2025
Series 65
BUSINESS BACKGROUND
Halter Ferguson Financial, January 2026 to Present, Equity Analysis Associate
Halter Ferguson Financial, September 2025 to December 2025, Equity Analysis Consultant
Annex Wealth Management, June 2025 to August 2025, Compliance Intern
Concordia University Wisconsin, August 2022 to December 2025, Full-Time Student
Big Lots, November 2021 to November 2022, Cashier
HankBreaksCards, March 2020 to October 2022, Owner
Item 3: Disciplinary Information
Not applicable.
Item 4: Other Business Activities
Not applicable.
Item 5: Additional Compensation
None.
Item 6: Supervision
Only the firm professionals Bradford S. Ferguson, CFA, Tiffany White, CFP®, Matthew Smith, Benjamin
Weber, Isaac Yops, and Henry Dierkes provide advice to clients. Matthew Smith, Chief Compliance
Officer, is responsible for all supervision. His phone number is 317-875-0202. As part of this role, Mr.
Matthew Smith does quarterly spot checks of financial plans and investment reviews being presented to
each client. Matthew Smith reviews all written client performance materials and newsletters prior to
use. On a weekly basis, the investment team meets to discuss investment strategies and market
conditions.
27