HANTZ FINANCIAL SERVICES, INC.

ITEM 1: COVER PAGE Hantz Financial Services, Inc. 26200 American Drive Fifth Floor Southfield, Michigan 48034 248.304.2855 www.hantzgroup.com August 29, 2025 This brochure provides information about the qualifications and business practices of Hantz Fi- nancial Services, Inc. (also referred to as “HFSI”, “we”, “us”, and “our” in this brochure). If you have any questions about the contents of this brochure, please contact us at 248.304.2855. 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 Hantz Financial Services, Inc. is available on the SEC’s website at www.adviserinfo.sec.gov. Registration as an investment adviser does not imply a certain level of skill or training. Hantz Financial Services, Inc. Firm Brochure  ITEM 2: SUMMARY OF MATERIAL CHANGES In this brochure, references to “we,” “us,” “our,” or “our firm” refer to Hantz Financial Services, Inc. (“HFSI”). Our related companies are referred to as “affiliates.” Individuals who serve as directors, officers, and employees are referred to as “representatives” of our firm or our affiliates. Our firm’s clients and prospective clients are referred to as “you,” “your,” or “our clients.” This section summarizes material changes that have been made to our Form ADV Part 2A (our “firm brochure”) since the date of its last annual version which was made available upon re- quest and/or distributed to our clients beginning March 14, 2025. Complete copies of our cur- rent firm brochure, and any of our brochure supplements for our investment adviser representa- tives (“representatives” or “planners”), are available upon request. Since its last distribution, there have been material changes to our business operations affecting the content in our firm brochure, including the following: 1. Item 4: Advisory Business – Inclusion of additional private equity investment opportuni- ties available to Hantz’s clients. 2. Item 5: Fees and Compensation – Description of potential fees and conflicts related to Hantz’s private equity investment offerings. 3. Item 6: Performance-Based Fees and Side-By-Side Management – Addition of Hantz Alternatives Management Company, LLC’s right to negotiate participation fees or carried interest in relation to Private Equity Offerings. 4. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss – Addition of Hantz Financial Services, Inc.’s use of Photon Insights, Inc., a generative artificial intelligence tool that aids in the aggregation and analysis of client data. 5. Item 14: Client Referrals and Other Compensation – Removal of Hantz Financial Ser- vices, Inc.’s conflict of interest with the parent company of Brooklyn Investment Group, LLC. 6. Item 14: Client Referrals and Other Compensation – Inclusion of the annual maximum fee associated with a customer’s engagement with Future Capital, Inc., as well as mention of Hantz Group’s convertible note to ProNvest, doing business as Future Capital. 7. Item 14: Client Referrals and Other Compensation – Mention of Hantz Group’s invest- ment in Photon Insights, Inc., a generative artificial intelligence tool. To request copies of the complete firm brochure, or any of our advisor’s brochure supplements, please contact our Chief Compliance Officer at the address or telephone number listed on the cover page of this document. Hantz Financial Services, Inc. - ii - Firm Brochure  ITEM 3: TABLE OF CONTENTS ITEM 1: COVER PAGE .................................................................................................................. i ITEM 2: SUMMARY OF MATERIAL CHANGES ..................................................................... ii ITEM 3: TABLE OF CONTENTS ............................................................................................... iii INTRODUCTION .......................................................................................................................... 1 ITEM 4: ADVISORY BUSINESS ................................................................................................ 1 ITEM 5: FEES AND COMPENSATION .................................................................................... 13 ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT............... 26 ITEM 7: TYPES OF CLIENTS ................................................................................................... 26 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS ....................................................................................................................................................... 26 ITEM 9: DISCIPLINARY INFORMATION .............................................................................. 31 ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............... 31 ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING ..................................................................... 33 ITEM 12: BROKERAGE PRACTICES ...................................................................................... 34 ITEM 13: REVIEW OF ACCOUNTS ........................................................................................ 39 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ....................................... 41 ITEM 15: CUSTODY .................................................................................................................. 44 ITEM 16: INVESTMENT DISCRETION ................................................................................... 44 ITEM 17: VOTING CLIENT SECURITIES ............................................................................... 45 ITEM 18: FINANCIAL INFORMATION .................................................................................. 45 Hantz Financial Services, Inc. - iii - Firm Brochure  INTRODUCTION In this brochure, references to “we,” “us,” “our,” or “our firm” refer to Hantz Financial Services, Inc. (“HFSI”). Our related companies are referred to as “affiliates.” Individuals who serve as directors, officers, and employees are referred to as “representatives” of our firm or our affiliates. Our firm’s clients and prospective clients are referred to as “you,” “your,” or “our clients.” This brochure contains important information. We encourage you to read it carefully and ask questions if it contains information that you do not understand. The format and content of this brochure have been prepared in accordance with the instructions to Form ADV, Part 2A. Form ADV, Part 2A is prescribed for use by registered investment advisers under federal and state securities laws and related rules and supersedes the older Form ADV, Part II. ITEM 4: ADVISORY BUSINESS HFSI has been in business since June 23, 1998. We are owned by a parent company, Hantz Group, Inc., whose majority shareholder is John R. Hantz. We offer services as an investment adviser, broker-dealer, and mortgage broker. We offer a va- riety of investment advisory services to our clients, including financial planning, investment portfolio management services, and retirement plan services. We tailor our advice and services to the stated objectives of each of our clients. Our affiliates and our representatives offer other services described throughout this brochure. Financial Planning Services Our financial planning and consulting services are offered in three different packages: (1) the Horizon Planning Service; (2) the Premier Planning Service; and (3) the Premier Busi- ness Planning Service. For each of these service packages, we gather information through in-depth personal in- terviews with you. This may include one or more in-person meetings and/or telephone calls. We may gather information that includes, but is not limited to, your current financial position, future goals and attitudes toward risk, and investment objectives. We ask you to fill out a client profile questionnaire that we will carefully review, along with all other documentation you supply. Because we do not independently verify, and instead rely only upon the information you provide to us, it is imperative that you update information that impacts your financial condition whenever it changes. Based on the information you provide, we will initially provide our advice in the form of a written financial plan. You should review the financial plan carefully and ask questions. The financial plan is de- signed to help you achieve your stated financial goals and objectives, but there can be no assurance that you will attain those goals and objectives because of many variables be- yond our control. Hantz Financial Services, Inc. - 1 - Firm Brochure  If you choose to implement your financial plan, we recommend that you work closely with a team of qualified professionals, which may include a securities broker, insurance agent, tax advisor, accountant, and attorney. You are not obligated to use our services, or the services of our affiliates and representatives, to implement any part of your financial plan. If you choose to implement our recommendations, you will incur additional costs that are not covered by our financial planning and consulting fees, as described below under the section heading, “Fees and Compensation.” Horizon Planning Service™ This package of our basic planning services typically includes an analysis and presentation of the following topics that are pertinent to individuals: financial po- sition, protection planning, basic investment planning, retirement planning, estate planning (excluding legal services), and income tax considerations (excluding tax return preparation services). These basic financial planning services are all pro- vided by us. Premier Planning Service™ This package of our advanced planning services typically includes an analysis and presentation of the following topics that are pertinent to higher net worth individ- uals and business owners: ● Financial position (including assets and liabilities, in- come and expenses, and debt strategies); ● Asset protection planning (including disability income, survivor income, long term care, home, auto and lia- bility insurance, business owner concerns); ● Investment planning (including asset alloca- tion, accumulation goals, and education plan- ning); ● Retirement planning (including income and expenses, lump sum distribution planning, and business owner con- cerns); and Estate planning (excluding legal services). ● This package includes income tax planning and tax return preparation by Hantz Tax & Business, LLC, or another of our Tax and Business Consulting Affiliates specified in the Financial Planning and Consulting Services Agreement. Hantz Financial Services, Inc. - 2 - Firm Brochure  Premier Business Planning Service™ This package of our advanced planning services typically includes an analysis and presentation of the following topics that are pertinent to businesses and business owners: ● Business accounting services (including accounting and tax preparation); ● Entity structure (including liability, tax implications, and ownership and entity review); ● Executive compensation analysis (including selec- tive benefits, ownership percentage, and key em- ployees); ● Qualified retirement plans (including employer funded plans, employee funded plans, and maxi- mum owner contributions); and ● Succession planning (including buy-sell and related key person insurance arrangements, and transition strategies). You are able to select the specific services you desire and they will also be speci- fied in the Financial Planning and Consulting Agreement that we will enter into with you. These consulting services are provided by our affiliates, Hantz Tax & Business, LLC, or the Tax and Business Consulting Affiliate specified in the Fi- nancial Planning and Consulting Services Agreement. However, HFSI provides all financial planning and investment advisory services. Termination of Financial Planning Services You may terminate our services without incurring any fee or penalty within the first five business days after you sign our Financial Planning and Consulting Agreement. After the initial five-business day period, you or we may terminate the contract by giving five business days’ written notice for any reason or no reason. Upon termination of our Financial Planning and Consulting Agreement, we will refund your prepayment for services if no services have been performed. We typ- ically will not refund client payments if we have already performed substantial services in the engagement. If you terminate our services after we have delivered the financial plan and performed our services, you are responsible to pay the re- maining balance due. Hantz Financial Services, Inc. - 3 - Firm Brochure  Retirement Plan Services If you are a retirement plan sponsor, we offer retirement plan consulting services to assist you in meeting your fiduciary obligations to your company sponsored Defined Contribu- tion Plan or Defined Benefit Plan. We can provide these services either on an ongoing basis or by way of a specific or one-time project-based request. Through interviews with the appropriate individuals at your company, we identify and confirm, together with you, targeted goals and objectives. Based upon information you provide, we are able to offer fiduciary and non-fiduciary services for your selection, as needed. Fiduciary services, as defined under 3(21)(A) of the Employee Retirement Income Secu- rity Act of 1974 (“ERISA”), are provided under a Retirement Plan Services Agreement and Investment Manager Services, as defined in Section 3(38) of ERISA, under a Discre- tionary Investment Management Agreement (collectively “Retirement Plan Consulting Agreements”). A Retirement Plan Consulting Agreement is provided prior to the start of our relationship and dependent upon your selections, may include the following services: ● Develop or supply assistance to develop, document, and review your plan’s investment policy; ● Recommendations regarding the retention, selection, or termination of certain designated investment alternatives and/or qualified de- fault investment alternatives in accordance with your plan’s guide- lines; and ● Preparation and presentation of periodic investment measurement re- ports for your plan. These reports typically include analyses and rec- ommendations regarding (1) the current investment market environ- ment, as well as possible future market trends; (2) manager perfor- mance and asset allocation; (3) reporting provided by Custodians and Administrators; (4) investment performance and investment costs of current selections compared to benchmarks and market averages. ● Provide participant level advice to your current employees in the plan if you select that service in the Participant Advice Supplement (“Sup- plement”) to our agreement with you. If you select participant level advice, each employee seeking individual advice will in turn sign a separate Participant Acknowledgement electing to utilize the service while actively employed by the plan sponsor. Participant level advice is only applicable to participant account(s) held within the retirement plan while the participant is employed by your company. Hantz Financial Services, Inc. - 4 - Firm Brochure  Through interviews with employee participants who desire our advice, our representatives will gather information regarding their time hori- zon, risk tolerance, and investment goals. Based on the information obtained, our representatives will provide non-discretionary invest- ment recommendations to the plan participant in regards to their re- tirement plan account. Non-discretionary investment advice means that the participant must choose whether to follow and implement the advice or recommendations that we provide to them. ● Select, monitor, remove, and replace the Plan’s Designated Investment Alternatives, including the plan’s qualified default investment alterna- tive, consistent with the Plan’s IPS or written investment objectives. ● Non-fiduciary consulting services may include services regarding plan design, service provider evaluation, training, and participant educa- tion. Termination of Retirement Plan Services As the plan sponsor, you may terminate the Retirement Services Consulting Agreement without incurring fees or penalties within 5 business days after enter- ing into this contract. After 5 business days, you or we may terminate the Retirement Plan Consulting Agreement by providing 15 days’ prior written notice. The Agreement will then terminate on the month end immediately following the 15-day notice period (“Termination Date”). We will prorate our compensation to the Termination Date. With the exception of any compensation due and owing upon termination, we do not have any additional termination charges or termination fees. After the Termination Date, we will have no further duties or obligations to the Plan. The participant level advice Supplement may be terminated at any time by you or us upon 10 business days’ prior written notice. After termination of the Supple- ment, participant advice will no longer be available to plan participants. An employee of a plan sponsor may also individually select to terminate their Participant Acknowledgment at any time by sending written notice to us at our address on the cover of this brochure. We will also discontinue providing partici- pant advice when an employee ends his or her employment with you or your affil- iates. Investment Portfolio and Wealth Management Services We offer portfolio management services in which we manage your investment assets based upon your individual financial and personal needs, investment objectives, time horizon, and risk tolerance. Our investment management services generally include allo- cating your assets in accordance with one or more of our model portfolios (referred to as Hantz Financial Services, Inc. - 5 - Firm Brochure  Representative-as-Portfolio Manager, or RPM), all of which employ the use of a broad range of no-load or load-waived mutual funds, exchange-traded funds (“ETFs”), and sep- arately managed accounts by third-party money managers. A model portfolio is how we communicate to you what specific investments you should have in your portfolio at any given time, depending on your investment objectives and risk tolerance, among other fac- tors. We will typically provide quarterly rebalancing services to your portfolio to help maintain the asset allocation consistent with the model portfolio(s) selected for your ac- count. To enhance the speed and efficiency of RPM trading, reconciliation, and related services, we utilize the services of an unaffiliated “Turnkey Asset Management Platform” (“TAMP”), SmartX Advisory Solutions, LLC, an SEC-registered investment adviser (https://adviserinfo.sec.gov/firm/summary/297680). We will use the TAMP to direct the execution and reconciliation of the trades performed in your RPM account. On occasion and where suitable for you, we may also allocate your assets among alterna- tive investments, including privately placed securities such as hedge funds, private equity funds, and real estate funds. Additional differences in holdings may stem from legacy securities transferred into the account, cash available for the purchase of securities and gradients of risk tolerance that you may request within the same investment objective. The history, timing, and sometimes unique holdings in your account may result in your investment returns being different from other clients with the same or similar investment objective. In certain cases, we may also provide investment advisory services to you within your ERISA covered retirement plan. These services include, but are not limited to analysis of plan investment options, implementation of reallocation recommendations and general ac- count servicing. Our ability to provide these services to you will be set forth in the written Investment Advisory Agreement that you will enter into with us which will include the scope of services to be provided as well as the cost of those services. You are under no obligation to employ our services in your ERISA covered plan. Because we tailor our advisory services to meet your individual needs and seek on a con- tinuous basis to ensure that your portfolio is managed in a manner consistent with your needs and objectives, we will consult with you on an initial and ongoing basis to assess your specific risk tolerance, time horizon, liquidity constraints, and other related factors relevant to the management of your portfolio. As a result, we require your active partici- pation while we formulate advice and recommendations. We do not verify the accuracy of the data you provide. We assume that the information you provide is reliable and cur- rent. We may also request the names and relationships of other advisors (e.g., attorney, accountant, banker, etc.). You should promptly notify us whenever there are changes in your financial situation or if you wish to place any limitations on the management of your portfolio. We are able to manage your assets on a discretionary or non-discretionary basis, as deter- mined by you and as set forth in the written Investment Advisory Agreement that you Hantz Financial Services, Inc. - 6 - Firm Brochure  will enter into with us. When managing assets on a discretionary basis, we will deter- mine the portfolio for your account consistent with your stated investment objectives and risk tolerance. You may also provide us with written guidelines and restrictions with re- spect to our authority to invest in certain securities or types of securities so long as they are reasonable and do not materially affect the performance of a model portfolio manage- ment strategy or prove overly burdensome to our management efforts. If we manage your assets on a non-discretionary basis, then you will retain the authority to make the investment decisions prior to our implementing them. See Item 16, entitled, “Investment Discretion” for more information. Our Investment Advisory Agreement may be terminated by you or us at any time by providing the other party with five business days written notice. Advisor will not prorate or refund pre-paid advisory fees, which are deemed fully earned at the beginning of each monthly billing period. Termination of an Investment Advisory Agreement will not affect any liabilities or obli- gations we have incurred or that have arisen from transactions initiated under the agree- ment prior to the termination date, such as the purchase of investments by us for your ac- count. You remain responsible for any cost incurred in transferring assets from your ac- count to a different account or custodian. After the date the agreement terminates, we will have no further duties or obligations to you under the agreement. Globally Diversified Dynamic ETF Model Portfolios (“Dynamic Model(s)”) The HFSI Globally Diversified Dynamic ETF Model Portfolios we offer have been de- signed around SEC-registered exchange-traded products (ETPs), primarily including ex- change traded funds (ETFs), with various investment characteristics and parameters of- fering a series of investment options for our clients across five levels of risk and volatil- ity, each level having an anticipated range of risk and volatility driven by the underlying securities held by the ETPs and ETFs. Typically, future prospects for greater investment returns bear greater risks, commonly reflected in price and trading volatility, including potential loss of income and principal. Our assessment of the relative risks and volatility of different categories of investments, as well as specific investments, are affected by many variables beyond our control and represent our professional judgment that under no circumstances can be guaranteed or as- sured. Each of our Dynamic Model portfolios includes varying asset allocations among different ETPs and ETFs having different investment characteristics and risks including, among others (i) domestic and foreign equities of issuers having varying levels of capitalization, investment characteristics, historical performance, and other considerations; and (ii) fixed income securities issued by federal, state, and local governments and corporate issuers with varying levels of capitalization, investment characteristics, credit enhancements, credit histories, and other credit-related considerations. Historical performance and credit histories do not assure the future performance of those securities. Hantz Financial Services, Inc. - 7 - Firm Brochure  We call each of our Dynamic Model portfolios an “Hantz Dynamic Global Allocation ETF Gear.” Each Hantz Dynamic Global Allocation ETF Gear has been designed within specific investment-related parameters that, in our professional judgment, pertain to its relative level of market, price, and liquidity risks, returns, and volatility. Our Dynamic Global Allocation ETF Gears range from 1 to 5 based on our assessment of its anticipated risks and volatility. In our judgement, we classify the comparatively lowest anticipated risk and volatility as “Hantz Dynamic Global Allocation ETF Gear 1” and the highest as “Hantz Dynamic Global Allocation ETF Gear 5”. Higher Gears have greater asset alloca- tions to equity securities than fixed income securities. Risk and volatility are very important among the various investment-related considera- tions potentially affecting anticipated investment performance. See Item 8, Methods of Analysis, Investment Strategies and Risk of Loss, as amended from time to time, for addi- tional information regarding our investment strategies, practices, and related risk consid- erations. Typically, once each year, and in special cases more frequently, the model composition and allocation weights may be adjusted. See Item 4, Advisory Business, for additional in- formation. Globally Diversified Active ETF Model Portfolios (“Active Model(s)”) The HFSI Globally Diversified Active ETF Model Portfolios we offer have been de- signed around SEC-registered exchange-traded products (ETPs), primarily including ex- change traded funds (ETFs), with various investment characteristics and parameters of- fering a series of investment options for our clients across five levels of risk and volatil- ity, each level having an anticipated range of risk and volatility driven by the underlying securities held by the ETPs and ETFs. Typically, future prospects for greater investment returns bear greater risks, commonly reflected in price and trading volatility, including potential loss of income and principal. Our assessment of the relative risks and volatility of different categories of investments, as well as specific investments, are affected by many variables beyond our control and represent our professional judgment that under no circumstances can be guaranteed or as- sured. Each of our Active Model portfolios includes varying asset allocations among different ETPs and ETFs having different investment characteristics and risks including, among others (i) domestic and foreign equities of issuers having varying levels of capitalization, investment characteristics, historical performance, and other considerations; and (ii) fixed income securities issued by federal, state, and local governments and corporate issuers with varying levels of capitalization, investment characteristics, credit enhancements, credit histories, and other credit-related considerations. Historical performance and credit histories do not assure the future performance of those securities. Hantz Financial Services, Inc. - 8 - Firm Brochure  We call each of our Active Model portfolios an “American Drive Model Portfolio Ac- tively Managed ETF Gear.” Each American Drive Model Portfolio Actively Managed ETF Gear has been designed within specific investment-related parameters that, in our professional judgment, pertain to its relative level of market, price, and liquidity risks, re- turns, and volatility. Our American Drive Model Portfolio Actively Managed ETF Gears range from 1 to 5 based on our assessment of its anticipated risks and volatility. In our judgement, we classify the comparatively lowest anticipated risk and volatility as “Amer- ican Drive Model Portfolio Actively Managed ETF Gear 1” and the highest as “American Drive Model Portfolio Actively Managed ETF Gear 5”. Higher Gears have greater asset allocations to equity securities than fixed income securities. Risk and volatility are very important among the various investment-related considera- tions potentially affecting anticipated investment performance. See Item 8, Methods of Analysis, Investment Strategies and Risk of Loss, as amended from time to time, for addi- tional information regarding our investment strategies, practices, and related risk consid- erations. Typically, once each year, and in special cases more frequently, the model composition and allocation weights may be adjusted. Each model targets specific investment alloca- tions. Rebalancing is important for keeping your intended level of risk consistent as mar- kets fluctuate and asset classes drift too far from the model’s target. Accordingly, Active Models will be reviewed, and allocations adjusted annually. Active Models will also be monitored for drift and rebalanced, as needed, based on both downward and upward drift from the model’s target allocations. See Item 4, Advisory Business, for additional infor- mation. Hantz Index Global Allocation ETF Models (“Index Model(s)”) The Hantz Index Global Allocation ETF Models we offer have been designed around SEC-registered exchange-traded products (ETPs), primarily including exchange traded funds (ETFs), with various investment characteristics and parameters offering a series of investment options for our clients across five levels of risk and volatility, each level hav- ing an anticipated range of risk and volatility driven by the underlying securities held by the ETPs and ETFs. Typically, future prospects for greater investment returns bear greater risks, commonly reflected in price and trading volatility, including potential loss of income and principal. Our assessment of the relative risks and volatility of different categories of investments, as well as specific investments, are affected by many variables beyond our control and represent our professional judgment that under no circumstances can be guaranteed or as- sured. Each of our Index Models includes varying asset allocations among different ETPs and ETFs having different investment characteristics and risks including, among others (i) do- mestic and foreign equities of issuers having varying levels of capitalization, investment Hantz Financial Services, Inc. - 9 - Firm Brochure  characteristics, historical performance, and other considerations; and (ii) fixed income se- curities issued by federal, state, and local governments and corporate issuers with varying levels of capitalization, investment characteristics, credit enhancements, credit histories, and other credit-related considerations. Historical performance and credit histories do not assure the future performance of those securities. We call each of our Index Models a “Hantz Index Global Allocation ETF Model Gear.” Each Hantz Index Global Allocation ETF Model Gear has been designed within specific investment-related parameters that, in our professional judgment, pertain to its relative level of market, price, and liquidity risks, returns, and volatility. Our Hantz Index Global Allocation ETF Model Gears range from 1 to 5 based on our assessment of its anticipated risks and volatility. In our judgement, we classify the comparatively lowest anticipated risk and volatility as “Hantz Index Global Allocation ETF Model Gear 1” and the highest as “Hantz Index Global Allocation ETF Model Gear 5”. Higher Gears have greater asset allocations to equity securities than fixed income securities. Risk and volatility are very important among the various investment-related considera- tions potentially affecting anticipated investment performance. See Item 8, Methods of Analysis, Investment Strategies and Risk of Loss, as amended from time to time, for addi- tional information regarding our investment strategies, practices, and related risk consid- erations. Typically, once each year, and in special cases more frequently, the model composition and allocation weights may be adjusted. Each model targets specific investment alloca- tions. Rebalancing is important for keeping your intended level of risk consistent as mar- kets fluctuate and asset classes drift too far from the model’s target. Accordingly, Index Models will be reviewed, and allocations adjusted annually. Index Models will also be monitored for drift and rebalanced, as needed, based on both downward and upward drift from the model’s target allocations. See Item 4, Advisory Business, for additional infor- mation. Separately Managed Accounts (“SMAs”) and Unified Managed Accounts through Third-Party Money Managers (“Third-Party SMA Managers Program”) We make available SMAs of several third-party investment managers (“Third-Party SMA Managers”) through our Third-Party SMA Managers Program. Typically, these Third- Party SMA Managers are participants in the Schwab Advisor Network platform (“Schwab Platform”) managed by Charles Schwab & Co (“Schwab”), that also serves as the client-directed broker-dealer and account custodian. In the future, we may select other investment advisers participating in our Third-Party SMA Managers Program. We “man- age the managers” in the Program on a discretionary basis, so we may change participat- ing Third-Party SMA Managers from time to time. Unlike mutual funds or ETFs, when you invest in an SMA, you will own a portfolio of individual securities under the management of an independent, unaffiliated, third-party investment adviser who is responsible for the day-to-day investment decisions for your Hantz Financial Services, Inc. - 10 - Firm Brochure  portfolio. Commonly, Third-Party SMA Managers deliver their investment management services through their use of model investment portfolios of various types and having various investment strategies. Each Third-Party SMA Manager is solely responsible for its own investment decisions, as well as its own actions and omissions. In providing SMA services, your representative will typically obtain the necessary finan- cial data from you to assist our Asset Management Team in determining appropriate in- vestment objectives and selecting one or more Third-Party SMA Managers whose invest- ment style and talent best fit your individual needs and circumstances. Your representa- tive will also assist you in opening an SMA account with the Third-Party SMA Manager. Our Asset Management Team will assist you in selecting a model portfolio of securities and a suitable Third-Party SMA Manager to provide discretionary asset management services. To enhance the speed and efficiency of Third-Party SMA Managers trading, reconcilia- tion, and related services, we utilize the services of an unaffiliated “Turnkey Asset Man- agement Platform” (“TAMP”), SmartX Advisory Solutions, LLC, an SEC-registered in- vestment adviser (https://adviserinfo.sec.gov/firm/summary/297680). Third-Party SMA Managers use the TAMP to direct the execution and reconciliation of the trades per- formed in your SMA. The TAMP will receive Third-Party SMA Manager instructions (“Model Signals”) periodically as to how your portfolio should be constructed and re- balanced from time to time. Under our Third-Party SMA services, our Asset Management Team provides ongoing investment monitoring and advice tailored to your individual needs and as described below in “Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss.” You should understand that it is both the Third-Party SMA Manager and/or the TAMP (and not HFSI or your representative) that has authority to purchase and sell specific securities on a discretionary basis according to the investment objective you choose after evaluating our recommendations. This authorization will be set out in the SMA and/or Managed Account client agreement. When engaging Third-Party SMA Managers made available by Schwab, your agreement with Schwab and/or the Third-Party SMA Manager gives us the authority to hire or fire these managers on your behalf. Once a manager is selected, your representative and our Asset Management Team will continue to monitor their performance, investment strate- gies, and target allocations to remain aligned with our clients’ investment objectives, risk tolerance, and overall best interests. From time to time, we may change the Third-Party SMA Manager with respect to specific investment strategies and, when that occurs, we will give you notice of the change. Additionally, we will meet with you, at least annually, to determine whether any changes in your financial status warrant adjustments to your investment objectives with the third- party money manager or whether there should be a change in the manager(s). We will also be happy to meet with you more frequently, if needed. Hantz Financial Services, Inc. - 11 - Firm Brochure  If you are interested in learning more about any of these participating Third-Party SMA Managers services, a complete description of their programs, services, fees, payment structure, and termination features are found in their respective service disclosure bro- chures, investment advisory agreements, and account opening documents, all of which we will provide to you prior to engaging their services. From time to time, we review other Third-Party SMA Managers, whether or not partici- pating in the Schwab Advisor Network, and we reserve the right to make different or additional investment advisers available through our Third-Party SMA Managers Pro- gram available to our clients as, in our discretion, we deem appropriate and consistent with our investment strategies. For accounts benefited from more complex investment strategies, we offer a unified solu- tion that allows for the consolidation of a wide range of investment portfolios and products, including SMAs, mutual funds, ETFs and individual securities to be held in a single in- vestment account. The unified account can hold and report on multiple third-party man- aged portfolio “sleeves” using investment model delivery along with an advisor-directed portfolio sleeve. This account type is commonly known in the securities industry as a “Unified Managed Account” (“UMA”). This “UMA Program” is custodied at Schwab. The Third-Party SMA Manager’s model delivery cost varies by manager – see Item 5, Fees and Compensation. Direct Indexing Models Hantz Financial Services, Inc. has partnered with Brooklyn Investment Group, LLC (“BKLN”), to provide Hantz clients technology-driven Direct Indexing services (Infor- mation on Brooklyn Investment Group, LLC can be found at https://advis- erinfo.sec.gov/firm/summary/316475. Direct Indexing is an investment strategy which in- volves buying individual stocks that make up an index, in similar proportions as the index. Direct Indexing offers several advantages over owning an index mutual fund or an index exchange-traded fund (index ETF), including greater flexibility and tax efficiencies. On an ongoing basis, the BKLN platform analyzes the end client portfolios for opportuni- ties to rebalance or tax-loss harvest the portfolio based on parameters or requests, tax-loss harvesting preferences, tracking error to the underlying benchmark(s), or other considera- tions. When a determination is made by BKLN that rebalancing is appropriate, trades to effectuate the rebalancing are executed on a discretionary basis. BKLN’s ongoing automated tax-loss harvesting is a feature which can be enabled for end investors, if certain conditions are met. Tax loss harvesting is the practice of selling an asset that has experienced a marked-to-market loss and replacing it with a basket of secu- rities that seeks to maintain portfolio characteristics vs. the selected benchmark subject to transaction costs and other considerations. By realizing, or “harvesting” the loss, Clients can seek to offset taxes on capital gains and income for an end investor, thereby potentially deferring tax liabilities. Hantz Financial Services, Inc. - 12 - Firm Brochure  Private Fund Management Hantz Financial Services, Inc. acts as an investment adviser to a private fund structured as a feeder fund to a master fund. The feeder fund’s sole investment is in the master fund. Private fund investments are offered exclusively to qualified clients. Should you qualify for and choose to invest in the private fund, Hantz Financial Services, Inc. encourages you to review the fund offering documents carefully. The fund documents will provide addi- tional information around fees, investment strategies, conditions for participating in the fund, capital calls, conflicts of interest, risk factors, and other material terms. Hantz may occasionally offer its clients opportunities to invest in other private equity op- tions, such as non-publicly traded stock, venture capital (VC), or what are commonly known as Angel Investments. Participation in these investments is exclusively available to qualified clients. Should you qualify for and choose to invest in these types of invest- ments, Hantz Financial Services, Inc. encourages you to carefully review the fund offering documents. The fund documents will provide additional information around fees, invest- ment strategies, conditions for participating in the fund, capital calls, conflicts of interest, risk factors, and other material terms. ITEM 5: FEES AND COMPENSATION Financial Planning Services Horizon Planning Service™ The annual fee for the Horizon Planning Service is specified in the Financial Planning and Consulting Agreement. This fee is renewable yearly if you wish to continue the financial planning and consulting services offered in this package. Additional information about the payment of our fees is described later in this section. Premier Planning Service™ The annual fee for our Premier Planning Service is specified in the Financial Plan- ning and Consulting Agreement and is subject to a variety of factors such as higher net worth, income, or complexity of your tax issues. This fee is renewable yearly if you wish to continue the financial planning and consulting services of- fered in this package. Upon request, we may negotiate fees based upon a variety of factors such as the complexity of your financial circumstances, any requests you may have affecting our cost of providing the services, the services we are providing for any related accounts, the longevity of our relationship, and the existence of any personal or Hantz Financial Services, Inc. - 13 - Firm Brochure  family relationships. The actual fee for the service will be specified in the Finan- cial Planning and Consulting Agreement. Information about the payment of our fees is described later in this section. Premier Business Planning Service™ The fee for our Premier Business Planning Service generally starts at $1,320. This fee is renewable yearly if you wish to continue the financial planning and consult- ing services offered in this package. This fee may be higher because of factors such as higher net worth, income, or the complexity of your tax issues, as well as the complexity, circumstances, and needs of the desired business consulting ser- vices. Upon request, we may negotiate fees based upon a variety of factors such as the complexity of your financial circumstances, any requests you may have af- fecting our cost of providing the services, the services we are providing for any related accounts, the longevity of our relationship, and the existence of any per- sonal or family relationships. The actual fee for the service will be specified in your Financial Planning and Consulting Agreement. Information about the payment of our fees is described later in this section. Additional Fee Information You must pay our initial financial planning and consulting fees at the time you complete and sign the Financial Planning and Consulting Agreement. You may pay our fees annually or in monthly installments through your bank from your checking account via the Automated Clearing House (ACH) Network. You must complete, sign and submit the ACH authorization form and give us a voided check from your checking account. We will only charge your account the specific in- stallment amount stated in the ACH authorization form. Your bank will report the charge in your periodic bank account statement. You can terminate this ACH au- thorization at any time by notifying us or your bank. We are not responsible for any overdraft charges that you may incur for insufficient funds in your checking account. You are responsible for all fees that are not paid by ACH transfer. We do not calculate or charge fees on the basis of a share of capital gains or capital appreciation of your funds or any portion of your funds. Renewal Fees We will renew your Financial Planning and Consulting Agreement yearly until you terminate the contract. You may terminate the contract by sending us written notice. The renewal fees in your contract will apply unless changed by mutual agreement because of changes in the factors we described above that affect our cost of providing these services. Renewal fees are paid in the same manner as described above. Hantz Financial Services, Inc. - 14 - Firm Brochure  Third-Party Fees and Charges You will incur additional fees and charges if you choose to implement our recom- mendations. Additional fees and charges typically include brokerage commis- sions, custodial fees, insurance commissions, program costs and other transaction- related charges. We will provide you, in advance, with information about those additional fees and charges. Fees and expenses charged by mutual funds or by insurance companies to their funds are separate and in addition to the fees we charge for our financial planning and consulting services. You will incur additional fees and charges at the fund level, if you purchase mutual fund shares or a variable insurance product. Each mutual fund or variable insurance product prospectus describes these fees and ex- penses. The additional fund-level fees may include, but are not limited to: a man- agement fee, other fund expenses, mortality and expense risk charge or possible distribution fee. If the product imposes a sales charge, you may pay an initial or deferred sales charge. Before investing, you should consider the total cost of fund-level fees, our advi- sory fees, program costs and any transaction-related commissions or charges. You may choose to invest in mutual funds or variable insurance products directly, with- out our services. Our representatives may receive continuing 12b-1 fees, sometimes called trail commissions, from mutual funds and insurance companies based on client funds held in those accounts. 12b-1 fees are described in each fund’s prospectus. In addition, our firm receives marketing allowances and reimbursements from pre- ferred suppliers, which may change from time to time. Recent marketing allow- ances and reimbursements are disclosed in our Disclosure of Possible Conflicts of Interest or in the investment or insurance product prospectus or brochure. A copy of our Disclosure of Possible Conflicts of Interest will be given to you in our new account documents when our relationship formally begins, and annually thereafter. It is also available upon request and can be found on the Hantz Group internet website at www.hantzgroup.com. For additional information about the compensation we may receive if you use our services to implement our advice, see the discussion under the heading below, “Client Referrals and Other Compensation.” Commissions and Sales Charges for Recommendations of Securities With respect to our financial planning services, if desired, you may engage certain of our registered representatives to render securities brokerage services, which will be under a separate written commission-based agreement with us. However, you Hantz Financial Services, Inc. - 15 - Firm Brochure  are under no obligation to do so and may choose brokers or agents not affiliated with us. In engaging us for securities brokerage services, our registered representatives may provide those services and implement securities transactions for your account at our firm. When we do so we will receive brokerage commissions, as well as a share of any ongoing distribution or service (12b-1) fees from the sale of mutual funds. We may also recommend no-load or load-waived funds, where no sales charges are assessed. However, prior to effecting any securities brokerage trans- actions, you are required to enter into a separate account agreement. A conflict of interest exists to the extent that we or our representative recommends the purchase or sale of securities where we receive commissions or other addi- tional compensation as a result of the recommendation. However, we have com- pliance supervisory procedures in place to help ensure that any recommendations made are suitable and in the best interest of clients. You are also welcome to discuss with us any concerns you may have about our conflicts of interest. Other Contract Terms and Amendments We may unilaterally amend the Financial Planning and Consulting Agreement, in- cluding our fee schedule. We will send you written notice of a change at least 30 days before its effective date. There is no penalty to you if you choose to discon- tinue our services because of the change. Simply notify us in writing of your de- cision to terminate our services before the effective date. You will remain respon- sible for services performed prior to the termination date. We will not “assign” the Financial Planning and Consulting Services Agreement to someone else without your consent, which you may give orally or in writing. We will imply your consent if all the following conditions are met: (1) We provide you at least 30 days’ prior written notice of the proposed assignment; (2) we pro- vide you with written confirmation that the assignment has occurred; (3) you do not respond objecting to the assignment; and (4) you do not terminate our services within 30 days after the effective date of the assignment. Retirement Plan Services Depending on the service(s) you select and if you would like to establish an ongoing relationship or project-based relationship, we may invoice our fees monthly or quarterly in advance or in arrears. We bill our investment advisory services in arrears on a monthly or quarterly basis, as selected in our agreement, and according to one of the following options: Fixed flat fee; or ● Hantz Financial Services, Inc. - 16 - Firm Brochure  Percentage of the assets. ● As the plan sponsor, you may pay invoiced fees directly or as a deduction from plan assets. Like many of our retirement plan clients, you may already have a relationship with a third-party custodian or record keeper of plan assets that requires or has the ability to establish ongoing authorization to have our fees deducted from plan assets. If you establish an automatic payment agreement from plan assets, we will not provide a monthly or quarterly invoice to the plan sponsor or third party. However, plan provided statements will reflect the fee payments. Our retirement plan consulting fees generally range from 5 basis points to 75 basis points of the value of plan assets, depending on factors of the plan and the service(s) you select. One basis point is equal to 0.01% of the amount. For example, 10 basis points is equal to 0.10%. Factors we consider in determining our fees include, but are not limited to: Amount of assets in the plan; ● Annual contributions to the plan; ● Investment committee experience and training; ● Number of employees and participants of the plan; and ● Complexity of the plan and services required. ● Hourly rates and one-time flat fees are dependent on the project-based service requested and professional knowledge required to perform such service. Hourly rates typically range from $100 per hour to $300 per hour. Flat one-times typically range from $100 to $30,000. Our fees are negotiable and all fees and payment methods, as agreed upon with you, will be described in our Retirement Plan Consulting Agreement with you. Renewal Fees We will automatically renew our Retirement Plan Consulting Agreement annually. You or we may terminate the contract by sending written notice to the other party. There is no penalty to you if you choose to discontinue our services. You will remain responsible for services performed prior to the termination date. The re- newal fees in your contract will apply unless changed by mutual agreement be- cause of changes in factors that affect our cost of providing services. Payment of fees will continue in the manner as selected in the most current agreement. Auto- matic renewal of fees does not apply to project-based agreements. Hantz Financial Services, Inc. - 17 - Firm Brochure  Third-Party Fees and Charges The plan sponsor, plan assets, and participants of the plan may incur additional fees and charges from third parties in addition to the fees for our services. Typi- cally, third-party fees and charges include recordkeeping fees, custodial fees, third party administration fees, and other transaction-related charges by parties that are separately engaged by the fiduciary to perform services. We will provide you, in advance, with information about additional fees and charges based on our recommendations and reviews. Fees and expenses charged by mutual funds, collective investment trusts, or by insurance companies to their funds are separate and in addition to the fees we charge for our retirement plan services. Additional fees and charges will be in- curred at the fund level as mutual fund and collective investment trust shares, or variable insurance separate accounts are purchased within the plan. Each mutual fund, collective investment trust, or variable insurance product’s prospectus de- scribes these fees and expenses. Before investing, you should consider the total cost of fund-level fees, our advi- sory fees, and any transaction-related commissions or charges. You may choose to invest in mutual funds, collective investment trusts, or variable insurance prod- ucts directly, without our services. Our representatives may receive continuing 12b-1 fees, sometimes called trail commissions, from mutual funds, collective investment trusts, and insurance com- panies based on client funds held in those accounts. 12b-1 fees are described in each fund prospectus. In addition, our firm receives marketing allowances and reimbursements from preferred suppliers, which may change from time to time. Recent marketing allowances and reimbursements are disclosed in our Disclosure of Possible Conflicts of Interest or in the investment or insurance product prospec- tus or brochure. For accounts covered by the Employee Retirement Income Se- curity Act of 1974 (“ERISA”) and such others that HFSI in its sole discretion deems appropriate, HFSI may provide its investment advisory services on a fee- offset basis. In this scenario, HFSI may offset its fees by an amount equal to the aggregate commissions and 12b-1 fees earned by our representatives in their in- dividual capacities as our registered representatives. A copy of our Conflicts of Interest Disclosure will be given to you in our new account documents when our relationship begins and annually thereafter. It is also available upon request and can be found on the Hantz Group internet site at www.hantzgroup.com. For additional information about the compensation we may receive if you use our services to implement our advice, see the discussion under the heading below, Cli- ent Referrals and Other Compensation. Hantz Financial Services, Inc. - 18 - Firm Brochure  Other Contract Terms We will not “assign” the Retirement Plan Services Agreement to someone else without your consent, which you may give orally or in writing. We will imply your consent if all the following conditions are met: (1) We provide you at least 30 days’ prior written notice of the proposed assignment; (2) we provide you with written confirmation that the assignment has occurred; (3) you do not respond ob- jecting to the assignment; and (4) you do not terminate our services within 30 days after the effective date of the assignment. Portfolio Management Services Annual fees for our portfolio management services are negotiable based upon the size and complexity of the account. Our standard investment management fee is generally based on the amount of assets under our management and varies between 20 and 100 basis points (0.20% - 1.00%), depending on the composition of your portfolio and the types of services you select. Alternatively, we may negotiate a fixed fee for our services in accordance with the monthly billing cycle described below. Advisor’s fees for the initial billing period will be billed when your Account is first opened based on your initial investment. Thereafter, Advisor’s fees are billed monthly in advance based on asset values reported by Client’s Custodian as of the end of the prior billing period. In view of the initial and on-going work performed for the Ac- count, fees are fully earned at the beginning of each monthly billing period. Prorated adjustments will not be made for either new investments in or withdrawals from the Account during a monthly billing period. No fee refunds will be made if assets are withdrawn or if the Account is terminated prior to a month-end. Additionally, for asset management services provided with respect to certain client hold- ings (for example, held-away assets, alternative investments, ERISA covered accounts, etc.), we may negotiate a fee rate with you that differs from the range set forth above and as set forth in your Investment Advisory Agreement. Advisor has established an agreement with TIAA-CREF in which it, and its investment advisor representatives, will have the authority to provide investment advisory services to certain plan participants who have authorized Advisor to act on their behalf. Accounts that Advisor has received authorization for will be billed a fixed-fee of 70 basis points (.70%) irrespective of account value or assets-under-management. Fee Negotiation We may, in our sole discretion, negotiate a lesser fee with you based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composi- tion, pre-existing or legacy client relationships, account retention, and pro bono activities. Hantz Financial Services, Inc. - 19 - Firm Brochure  Third Party Fees and Expenses Our fees are exclusive of brokerage commissions, transaction fees, and other re- lated costs and expenses that you may incur. For example, you may incur certain charges imposed by custodians, brokers or third-party sub-advisors. There may also be custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees and other fees and taxes on brokerage ac- counts and securities transactions. Mutual funds, exchange traded funds, and var- iable insurance products also charge internal management fees, which are dis- closed in their product prospectuses. Such charges, fees and commissions are ex- clusive of and in addition to our fee. Direct Billing to Client’s Custodian Generally, you will authorize us (and/or SMA advisors and/or the TAMP) under the Investment Advisory Agreement to directly deduct fees from your accounts held at the custodian. Your custodian’s periodic statements will show each fee deduction from your account. You may withdraw this authorization for direct billing of these fees at any time by notifying us or your custodian in writing. Account Additions and Withdrawals You may make additions to and withdrawals from your account at any time. Ad- ditions may be in cash or securities provided that we reserve the right to liquidate any transferred securities or decline to accept particular securities into your ac- count. You may withdraw account assets on notice to us, subject to the usual and customary securities settlement procedures. However, we generally design our portfolios as long-term investments. Consequently, the withdrawal of assets may impair the achievement of your investment objectives. We may consult with you about the options and implications of transferring securities. You should under- stand that when transferred securities are liquidated, they may be subject to trans- action fees, short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications. Globally Diversified Dynamic ETF Model Portfolio Fees In order for us to properly maintain the integrity of each Dynamic Model, consistent anal- ysis and diligence must be performed. This diligence includes the research, development and implementation of our Capital Market Expectations (“CMEs”). The CMEs are uti- lized in the application of strategic weightings based on each Hantz Dynamic Global Al- location ETF Gear which determine the rebalancing cadence. In addition to our on-going investment advisory fees, if you choose to allocate assets into one or more Dynamic Model(s), you will be assessed a Model Fee of .20% (or 20bps) on the value of assets held within one or more Dynamic Model(s). The Dynamic Model(s) Hantz Financial Services, Inc. - 20 - Firm Brochure  are provided on an “as-is” basis and the ETPs that make up the Dynamic Model(s) cannot be excluded. Globally Diversified Active ETF Model Portfolio Fees In order for us to properly maintain the integrity of each Active Model, consistent analy- sis and diligence must be performed. This diligence includes the research, development and implementation of our Capital Market Expectations (“CMEs”). The CMEs are uti- lized in the application of strategic weightings based on each American Drive Model Portfolio Actively Managed ETF Gear which determine the rebalancing cadence. In addition to our on-going investment advisory fees, if you choose to allocate assets into one or more Active Model(s), you will be assessed a Model Fee of .20% (or 20bps) on the value of assets held within one or more Active Model(s). The Active Model(s) are provided on an “as-is” basis and the ETPs that make up the Active Model(s) cannot be excluded. Hantz Index Global Allocation ETF Model Fees In order for us to properly maintain the integrity of each Index Model, consistent analysis and diligence must be performed. This diligence includes the research, development and implementation of our Capital Market Expectations (“CMEs”). The CMEs are utilized in the application of strategic weightings based on each Hantz Index Global Allocation ETF Model Gear which determine the rebalancing cadence. In addition to our on-going investment advisory fees, if you choose to allocate assets into one or more Index Model(s), you will be assessed a Model Fee of .20% (or 20bps) on the value of assets held within one or more Index Model(s). The Index Model(s) are pro- vided on an “as-is” basis and the ETPs that make up the Index Model(s) cannot be ex- cluded. Third-Party SMA Manager Services Your representative may recommend that you use a Third-Party SMA Manager in our SMA Program. When using a Third-Party SMA Manager, our advisory fee, which ranges from 0.12% to 1.00%, compensates your representative and us for the on-going monitoring and review of the manager’s performance. Your specific fee will be described in your Investment Advisory Agreement that you will enter into with us. In addition to our on-going investment advisory fees, as summarized below, the TAMP will bill Third-Party SMA Manager Program Fees comprised of (1) each Third-Party SMA Manager’s model delivery costs; (2) when applicable, the TAMP’s fees; and (3) our Program Fee that varies based on assets under management starting at 0.60% down to 0.54%. All Third-Party SMA Manager Program Fees are separate from and in addition to our advisory fee. Hantz Financial Services, Inc. - 21 - Firm Brochure  Schwab Advisors Network. For some Third-Party SMA Managers Schwab is acting as the broker-dealer and custodian with respect to any transactions in your SMA account. For these SMAs the Program Fee is a bundled fee arrangement that includes most of Schwab’s brokerage transaction costs and the Third-Party SMA Manager’s portfolio management services. Depending on the amount of assets under management and the asset class selected, the Third-Party SMA Man- ager Program Fees range from 0.25% to 1.00%. Other Third-Party SMA Managers. For other Third-Party SMA Managers we make available through our SMA Program, Schwab acts as the broker-dealer and custodian with respect to transactions in your SMA account. For these Third- Party SMA Managers, the Program Fee includes (1) the cost of using the TAMP’s services, (2) the Third-Party SMA Manager’s model delivery fee, and (3) our Third-Party SMA Program Fee, but does not include our advisory fees. Depend- ing on the amount of assets under management and the asset class selected, the Third-Party SMA Manager’s model delivery fees range from 0.01% to 0.55% and the TAMP’s costs range from 0.03% to 0.12%. Unified Managed Accounts (“UMA”). Using the TAMP, we offer a unified so- lution for more complex investment strategies that allows for the consolidation of a wide range of investment portfolios, products, including SMAs, mutual funds, ETFs and individual securities to be held in a single investment account. The account can include multiple third-party managed sleeves using model delivery. This UMA Program is custodied at Schwab. The Third-Party SMA Manager’s model delivery cost varies by manager starting at 0.01% up to 0.55%; the cost of using the TAMP’s services varies from 0.03% up to 0.12%. HFSI charges a pro- gram fee that varies based on assets under management starting at 0.60% down to 0.54%. In addition, as described above, HFSI will also charge an additional In- vestment Advisory fee which varies based on assets under management starting at .25% to 1.00%. Other Fees and Costs. The following other fees and expenses are generally not included in our fee or the program fee arrangement of the SMA (please refer to Schwab’s Managed Account Select & Managed Account Access Account Appli- cations for detailed information): ● Services provided by broker-dealers other than Schwab for transactions executed away from Schwab but settle into your SMA account at Schwab; ● Custody and set-up fees for non-standard assets such as non-publicly traded limited partnership interests, certain foreign securities, and non- marketable securities. Note that most non-standard securities are not eligible to be placed in a SMA account; Hantz Financial Services, Inc. - 22 - Firm Brochure  ● SEC exchange fees, ADR fees, transfer taxes, odd-lot differentials, mu- tual fund short-term redemption fees, certificate delivery fees, reorgani- zation fees, electronic funds or wire transfer fees, and any other similar costs and charges; and ● Management and administrative fees charged by mutual funds (includ- ing money market funds), closed-ended funds and ETFs, which are paid by the fund or ETF to its advisor and service providers, and which are borne pro rata by the mutual fund’s shareholders. Typically, Third-Party SMA Manager’s advisory fees and model delivery fees charged are not negotiable. To the extent that our Third-Party SMA Managers Program operates like a wrap fee program, you should understand that the bundled cost may be more than purchasing the Program’s component services separately. For example, paying fees for the advisory services of the Third-Party SMA Manager and us, plus commissions and ticket charges, for each transaction in the account. The investment products and services available through a Third-Party SMA Man- ager can generally be purchased by clients outside of a SMA account through broker-dealers or other investment firms not affiliated with us or the Third-Party SMA Manager. For further details, please be sure to review carefully the third-party manager’s disclosure brochures (or Wrap Fee Program Disclosure Brochure) and invest- ment program agreements that we will provide to you. Direct Indexing Models In order for us and Brooklyn Investment Group, LLC to properly maintain the integrity of each Direct Indexing Model, consistent analysis and diligence must be performed. In addition to our on-going investment advisory fees, if you choose to utilize and enable one or more Direct Indexing Model(s), you will be assessed a Model Fee of .20% (or 20bps) on the value of assets held within one or more Direct Indexing Model(s). The Di- rect Indexing Model(s) are provided on an “as-is” basis and the ETPs that make up the Direct Index Model(s) cannot be excluded. Account Type Disclosures As described above in this Item 5, we offer both commission-based brokerage and asset- based fee arrangements. None of our asset-based fee accounts cover brokerage services (i.e., all of our accounts are “fee-plus-commissions”). Your choice of investment-related services, described above in Item 4, typically drives the selection of your account type Hantz Financial Services, Inc. - 23 - Firm Brochure  because our investment-related services are, for the most part, only available using a par- ticular account type. For example, our financial planning services are only available for a fixed fee; our investment management services are only available in a fee-based account, as described above. Please ask us questions about our services and the related account types. Your total cost for investment-related services can vary significantly depending upon, among other things, the account type, the amount and type of investments you hold, and the custodian holding your assets, as summarized above in this Item 5. The selection of account type and related compensation arrangements typically depends upon, among other things, the investment-related services you are seeking, the amount of your investable assets, your investment goals, investment objectives, investment time horizon, and investment strategies, as described in Item 4 above. Our recommendation and your selection from among available investment services and related account types is an important discussion topic because it depends upon your cir- cumstances. As your circumstances change, you may be better served by moving to dif- ferent investment services with a different account type for some or all of your investable assets. Be sure to alert us to relevant changes in your circumstances. From time to time we may recommend changing your investment services and the related account types. Moving between commission-based and asset-based account arrangements can affect your total investment-related costs, which can have a significant impact on your total investment returns over time, so this is an important topic to discuss with your rep- resentative when you open an account and from time to time thereafter. Consultancy Agreement Services We have entered into Consultancy Agreements with several of our Investment Managers: Brandes Investment Partners, LP; Congress Asset Management Company; Polen Capital Management, LLC; and Segall Bryant & Hamill, LLC. As defined in these agreements, each Investment Manager serves as “Adviser”, and Hantz Financial Services, Inc. serves as “Consultant”. The Services rendered as part of these agreements will generally cover consultation and assistance with respect to the types and structures of ETFs; the processes for creating ETFs (“Creation Units”) and for redeeming Creation Units; management fee structures and re- lated economic considerations; advice regarding the selection of third parties to provide custodial services, distribution channels, and trading platforms; securities industry market- ing strategies with consideration of, among other matters, FINRA Rules applicable to FINRA-member broker-dealers distributing the Funds; the roles and responsibilities of Ad- viser and third-party vendors, respectively; selection criteria, due diligence, and engaging third-party vendors supporting the creation, administration, distribution, and custody of ETFs; selection criteria, due diligence, and engaging authorized participants and market makers; the process of listing ETFs on one or more exchanges, and other trading platforms; and other matters related to the start-up and implementation of the various decisions to be made by Adviser with respect to the Funds’ creating and operation. Hantz Financial Services, Inc. - 24 - Firm Brochure  The Funds being referred to and consulted on are to be made available for investment to Hantz clients, as well as the general investing public. The above-listed Advisers will pay to Consultant a quarterly fee in arrears based on the average of the asset value of each fund from the prior three months in the amount of 5 basis points (0.05%) (“Consultant’s Compensation”) from Adviser’s own resources and not from each Fund’s assets; provided, the calculation of Consultant’s Compensation will ex- clude, and will not be based, directly or indirectly, or otherwise contingent or dependent upon any measure of Consultant’s Clients’ assets under management or advisement that may be invested in the Funds. Our relationship with Advisers and ETF Sponsors creates a conflict of interest because we have an incentive to recommend the ETFs managed by and sponsored by the parties to these agreements. By referring clients to the ETFs sponsored by Advisers, we make more money, which could cause us to put our interests ahead of yours. However, we believe that we mitigate the conflict, as follows: • While the Consulting Agreement does provide Hantz with variable compensation (e.g., compensation that increases as the ETF’s assets under management increase), the ETF’s assets under management includes assets of many investors, including non-Hantz clients. • The compensation received pursuant to the Consultancy Agreement is provided in exchange for quantifiable consulting and support services, not client referrals. Additional information regarding this conflict of interest can be found in the respective Fund Sponsor’s prospectus. It is important that you understand any and all conflicts related to our advisory services. You are encouraged to contact our Chief Compliance Officer with any questions. Private Fund Management Fees As described in Section 4, Hantz Financial Services, Inc. acts as an investment adviser to a private fund structured as a feeder fund to a master fund. Hantz Alternatives Manage- ment Company, LLC receives a 10 basis point annual fee (0.1%), of which Hantz Finan- cial Services, Inc. earns a 2.5 annual basis point (0.025%) investment advisory fee for managing the assets of private funds (alternative investments) where Hantz serves as ad- viser to the fund. When referring you to a private fund, there is a conflict of interest based on our role as adviser to the fund and our affiliate, Hantz Alternatives Management Com- pany, LLC, serving as the fund management company/manager. Hantz Financial Services, Inc. receives compensation for referring investors to the fund. And, because Hantz Fi- nancial Services, Inc. and Hantz Alternatives Management Company, LLC are affiliates by common ownership, we have an interest in increasing assets managed by our affiliates to benefit our corporate entities and to increase our compensation. Additionally, Hantz Financial Services, Inc., our affiliated broker-dealer, has negotiated with the master fund management company a 50% participation in any of their performance fees. To address these concerns and mitigate the conflict, we provide full disclosure to you, and we have Hantz Financial Services, Inc. - 25 - Firm Brochure  established policies and procedures to ensure we only recommend products that are in your best interest. As described in Section 4, Hantz may occasionally offer its clients opportunities to invest in other private equity options, such as non-publicly traded stock, venture capital (VC), or what are commonly known as Angel Investments. Fees and expenses related to these investments may include Management Fees, Carried Interest, and Performance Participa- tion Fees, and they can vary from one investment to another. Clients are encouraged to carefully review the fund offering documents, as these will provide additional details about fees, investment strategies, conditions for participating in the fund, conflicts of in- terest, risk factors, and other terms. When referring you to these types of investments, there is a conflict of interest based on our role as adviser to the fund and our affiliate, Hantz Alternatives Management Company, LLC, serving as the fund management com- pany/manager. Hantz Financial Services, Inc. receives compensation for referring inves- tors to the fund. And, because Hantz Financial Services, Inc. and Hantz Alternatives Management Company, LLC are affiliates by common ownership, we have an interest in increasing assets managed by our affiliates to benefit our corporate entities and to increase our compensation. To address these concerns and mitigate the conflict, we provide full disclosure to you, and we have established policies and procedures to ensure we only recommend products that are in your best interest. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Hantz Financial Services, Inc.’s fees are outlined above. Hantz Alternatives Management Com- pany, LLC reserves the right to negotiate participation fees or carried interest in relation to our Private Equity Offerings. A comprehensive breakdown of fees and expenses is available in the fund offering documents provided to prospective investors. ITEM 7: TYPES OF CLIENTS Generally, we provide our financial planning and consulting services to individuals and their related IRAs, trusts, as well as businesses and their related pension or retirement plans. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS Methods of Analysis Our analysis begins with a review of your goals, time horizon, and risk tolerance through an interview process in an effort to determine a plan and/or portfolio that will best suit your needs. We design our financial planning services to, among other things, assist you in selecting investment, insurance, and other financial products and services that are ap- Hantz Financial Services, Inc. - 26 - Firm Brochure  propriate to your personal circumstances and financial objectives. We design our retire- ment plan investment services to assist plan sponsors in meeting their fiduciary responsi- bilities and adhering to the plan’s investment policy statement. Our primary method of security analysis involves fundamental analysis. Fundamental analysis is a technique that attempts to determine a security’s value by focusing on the financial and economic well-being of a particular issuer or fund as opposed to only its price movements. When conducting fundamental analysis, various factors are evaluated including, but not limited to a review of an issuer’s management team, investment strate- gies, style drift, past performance, reputation, and financial strength in relation to the asset class concentrations and risk exposures of our model asset allocations. For third-party money manager analysis for SMA services, we examine the experience, expertise, investment philosophies, and past performance of these third-party managers in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We monitor the manager’s underlying hold- ings, strategies, concentrations, and leverage as a part of our overall periodic risk assess- ment. Additionally, as a part of our due-diligence process, we survey the manager’s compliance and/or business enterprise risks. Investment Strategies In providing our investment advice to you, the concept of asset allocation or spreading investments among a number of asset classes (domestic stocks vs. international stocks; large company stocks vs. small company stocks; corporate bonds vs. government securi- ties) is generally at the forefront of our strategies since we believe that risk reduction is a key element to long-term investment success. At its heart, asset allocation is the imple- mentation of a diversified investment strategy that attempts to balance risk versus reward by adjusting the percentage of each asset in an investment portfolio according to a client’s risk tolerance, investment objectives, and investment time horizon. We primarily recommend implementing these strategies using a variety of ETFs, mutual funds, and SMAs to promote portfolio diversification within various asset classes, such as industry sectors, domestic/international, or stocks/bonds. We generally utilize a model portfolio strategy targeting different levels of risk and return objectives tailored to your specific goals and needs. Sometimes called rebalancing, we may recommend periodic purchases, sales, and exchanges within mutual fund families, between different mutual fund families or ETFs, as well as SMAs when there are changes in your needs, market conditions, or economic developments. While we use a proactive management process across multiple asset classes in our models, such diversification and management does not ensure a profit and may not protect against loss in declining markets. Types of Investments and Risk of Loss We offer advice about a variety of investment types, including SMAs, mutual funds, index funds, ETFs, as well as fixed and variable annuities, each having different types and levels Hantz Financial Services, Inc. - 27 - Firm Brochure  of risk. We will discuss these risks with you in determining the investment objectives that will guide our investment advice for your account. We will explain and answer any questions you have about these kinds of investments, which present special considerations such as the following described below in this section. Investing in securities involves risk of loss that you should be prepared to bear. Obtaining higher rates of return on investments typically entails accepting higher levels of risk. We work with you to attempt to identify the balance of risks and rewards that is appropriate and comfortable for you. However, it is still your responsibility to ask questions if you do not fully understand the risks associated with any investment or investment strategy. Also, while we strive to render our best judgment on your behalf, many economic and market variables beyond our control can affect the performance of your investments and we cannot assure you that your investments will be profitable or assure you that no losses will occur in your investment portfolio. Past performance is one relatively important con- sideration with respect to any investment or investment advisor, but it is not a predictor of future performance. Mutual Funds We often recommend mutual funds of different kinds to promote portfolio diversification within various asset classes, such as industry sectors, domestic/international, or equi- ties/bonds. We may recommend periodic purchases, sales, and exchanges of those mutual fund shares within mutual fund families and between different mutual fund families, when there are changes in your needs, market conditions, or economic developments. The different kinds of mutual funds we use each have inherently different risk character- istics and should not necessarily be compared side by side. A bond fund with below- average risk, for example, should not be compared to a stock fund with below average risk. Even though both funds have low risk for their respective categories, stock funds overall have a higher risk/return potential than bond funds. With respect to all classes of SMAs, mutual funds and ETFs, diversification does not protect you from an overall de- cline in the market. You should consider these risks in determining whether to use our services. Exchange-Traded Funds and Index Funds Exchange-traded funds (“ETFs”) represent a fractional ownership interest in an underly- ing portfolio of securities or commodities. Many exchange-traded funds are passively managed to track a specific market index and some are actively managed. Some invest in specific economic sectors, domestically or globally. Most ETFs combine characteristics of an open-end mutual fund and a stock. However, unlike mutual funds, individual in- vestors do not purchase or redeem shares from the fund. Instead, like stocks, individuals Hantz Financial Services, Inc. - 28 - Firm Brochure  buy and sell shares of ETFs on an exchange, including the American Stock Exchange, the New York Stock Exchange, and the Chicago Board Options Exchange. The trading dynamic is also a mixture of the two types of securities. That is, prices of ETFs fluctuate according to changes in their underlying portfolios and also according to changes in market supply and demand for ETF shares themselves. Unlike open end mu- tual funds, ETFs are not bought and sold by the fund’s underwriter at the daily net asset value. ETFs offer investors a cost-effective opportunity to obtain portfolio diversification by buying or selling an interest in a portfolio of stocks or bonds in a single transaction. Sometimes referred to as a “tracking error,” expenses and other factors may affect the performance of an index-oriented ETF so that the ETF’s performance will not exactly match the performance of their respective underlying indexes. Direct Indexing Hantz Financial Services, Inc. has partnered with Brooklyn Investment Group, LLC (“BKLN”), to provide Hantz clients technology-driven Direct Indexing services. Direct Indexing is an investment strategy which involves buying individual stocks that make up an index, in similar proportions as the index. Direct Indexing offers several advantages over owning an index mutual fund or an index exchange-traded fund (index ETF), includ- ing greater flexibility and tax efficiencies. On an ongoing basis, the BKLN platform analyzes the end client portfolios for opportuni- ties to rebalance or tax-loss harvest the portfolio based on parameters or requests, tax-loss harvesting preferences, tracking error to the underlying benchmark(s), or other considera- tions. When a determination is made by BKLN that rebalancing is appropriate, trades to effectuate the rebalancing are executed on a discretionary basis. BKLN’s ongoing automated tax-loss harvesting is a feature which can be enabled for end investors, if certain conditions are met. Tax loss harvesting is the practice of selling an asset that has experienced a marked-to-market loss and replacing it with a basket of secu- rities that seeks to maintain portfolio characteristics vs. the selected benchmark subject to transaction costs and other considerations. By realizing, or “harvesting” the loss, Clients can seek to offset taxes on capital gains and income for an end investor, thereby potentially deferring tax liabilities. Data provided to Brooklyn Investment Group, LLC is limited to an investor’s name, ac- count number, and related financial data, including assets under management and trades made within an investor’s account(s). This financial-related data assists Brooklyn in per- forming its direct indexing services, as discussed above. BNY Archer (or “Archer”) is Brooklyn Investment Group, LLC’s vendor, which provides Brooklyn with back-office support, account reconciliation and trade building to adequately facilitate the aforemen- tioned services to our end investors. Archer can be thought of as the interface with Hantz’s custodian, Charles Schwab, and has access to much of the same client data as Charles Schwab and Hantz. Archer collects Personally Identifiable Information and Account Data Hantz Financial Services, Inc. - 29 - Firm Brochure  directly from the Investment Manager through Secure FTP or direct feeds from trusted Custodians and Archer will use and process this data based on the agreed upon services. The Archer application is hosted by Microsoft Azure’s data center and colocation facilities located in the United States. Use of Independent Money Managers A risk of investing in an SMA with a third-party money manager who has been successful in the past is that the money manager may not be able to replicate that success in the future. In addition, even though we strive to conduct ongoing due diligence, we do not control the underlying investments in a third-party manager’s portfolio, so there is a risk that a manager may deviate from the stated investment mandate or strategy of the portfo- lio, making it a less suitable investment for our clients. Moreover, as we do not control the manager’s day-to-day business and compliance operations, we may be unaware of the lack of internal controls necessary to prevent business, regulatory, or reputational defi- ciencies. Private Funds As outlined in Section 4, Hantz Financial Services, Inc. acts as an investment adviser to a private fund structured as a feeder fund to a master fund. Investing in private funds or other private equity options carries substantial risks, as these investments are often illiq- uid, meaning you may not be able to access your funds once they are invested. Addition- ally, these investments typically offer limited redemption opportunities, if any, and there is a potential for complete loss of principal. Some qualified employees who invest in these fund(s) may also be shareholders of Hantz Group, Inc. Photon Insights, Inc. Hantz Financial Services, Inc. and its affiliates have entered into an agreement with Pho- ton Insights, Inc., a generative artificial intelligence tool, to assist in our aggregation and analysis of client data. Photon Insights aggregates and analyzes information from through- out the web as well as from custom data sources and surfaces using Machine Learning. From large amounts of both structured and unstructured data, Photon parses this vast in- formation and provides end-users with salient and concise insights. Its purpose is to pro- vide users pertinent information they need quickly and as early as practicable. For enter- prise users, including Hantz Financial Services, Inc., Photon provides customized views into our most important areas of interest, including information contained within a cus- tomer’s Financial Plan, Declaration Pages, Estate Documents, and more. Hantz Financial Services, Inc. is committed to ensuring accurate outputs provided by generative artificial intelligence tools and routinely reviews the material features and limitations of Photon In- sight, Inc. Under the terms of our agreement, Hantz may provide certain personal data to Photon in the course of Photon’s provision of Products and Services. Photon has agreed to handle such personal data in accordance with all relevant and applicable United States Hantz Financial Services, Inc. - 30 - Firm Brochure  laws and regulations relating to the handling of Personal Data and with Photon’s then cur- rent Privacy Policy. ITEM 9: DISCIPLINARY INFORMATION Hantz Financial Services, Inc. has no relevant disciplinary information to report. Additional information about Hantz Financial Services, Inc. is publicly available on the Invest- ment Adviser Public Disclosure website at: http://www.adviserinfo.sec.gov/ . ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Our Other Activities We are registered as a broker-dealer with the Securities and Exchange Commission (“SEC”), the State of Michigan, and other states. We are a member of the Financial In- dustry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corpora- tion. We are also licensed in Michigan, Illinois, Florida, Ohio, and Texas as a residential mort- gage broker. As part of the financial planning process, we may make recommendations involving refinancing, debt consolidation, debt reduction, or mortgage-related strategies retirement, children’s education and other expenses. If we to help provide funds for recommend mortgage financing or refinancing your existing debt, you are under no ob- ligation to do so and you may obtain financing through any lender of your choosing. If you choose to implement a mortgage strategy to generate investable funds, you will receive a disclosure pamphlet entitled, “Betting the Ranch: Risking your Home to Buy Securities” that outlines the risks associated with mortgaging your home. We originate mortgages to an affiliated lender. This lender compensates us based on the loan amount. This compensation is disclosed on the loan estimate and closing disclosure forms required by the Truth in Lending Act (“TILA”). We pay our licensed mortgage brokers based on the loan amount. This additional compensation creates potential con- flicts of interest, further discussed below under the section heading “Client Referrals and Other Compensation.” We may refer you to our other affiliates for various financially related products and ser- vices to implement various aspects of our recommendations. You have no obligation to purchase their products and services. Purchasing their products and services indirectly benefits us. The products and services offered by our affiliates are available from similar service providers, some of which could be at a lower cost than our affiliates may charge. Hantz Financial Services, Inc. - 31 - Firm Brochure  Our Tax and Business Consulting Affiliates Our Tax and Business Consulting Affiliates, listed below, provide the tax planning, con- sulting and, if applicable, tax return preparation services that are included in our service packages described above. Your Financial Planning and Consulting Agreement will specify, among other things, which of these firms will provide these services for you. Beyond our service packages, these affiliates provide other accounting, tax, and business consulting services to our clients and to the general public. Many of our representatives work through these affiliates to provide tax, accounting, or consulting services as a CPA, a tax practitioner, or an IRS Enrolled Agent. An IRS Enrolled Agent is a tax practitioner authorized to represent taxpayers before the Internal Revenue Service. Our Tax and Business Consulting Affiliates include: Hantz Tax & Business, LLC, Hantz Ewald, LLC, and Dynamic Tax Solutions, LLC. Our Parent Company and its Affiliates We are a wholly owned subsidiary of Hantz Group, Inc. of Southfield, Michigan. Through its various subsidiaries, Hantz Group, Inc. is engaged in a variety of businesses that offer financial, investment, accounting, insurance, tax, and related services that are listed below. Hantz Group, Inc. also owns other affiliates that are not financially-related businesses. Our directors and principal executive officers also serve in similar capacities with our affiliates and other Hantz-related companies. The amount of time they may devote in their executive and management capacities for these businesses varies as man- agerial time requirements may dictate. Hantz Group, Inc. is affiliated by common ownership with Hantz Holdings, Inc., a bank holding company headquartered in Southfield, Michigan (“Hantz Holdings”). Hantz Holdings owns Hantz Trust. Hantz Trust (“the Bank”) is a state-chartered, trust-only bank headquartered in South- field, Michigan. The Bank offers services of a corporate fiduciary, including serving as an institutional trustee, for a variety of trusts. The Bank does not make loans or accept deposits, and it is not FDIC insured. The Bank may refer clients to us and other affiliates for the financially-related services described in this brochure. We may refer you to the Bank for trustee -related fiduciary services. Your engagement of the Bank’s services indirectly benefits us and our affiliates. The Bank’s corporate fiduciary services are operationally independent from our investment advisory and brokerage services. Our Other Affiliates Our other affiliates include, and are engaged in, these financially-related businesses: Hantz Agency, LLC, and PLUS Agency, LLC are insurance agencies. Hantz Retirement Plan Solutions, LLC ● ● Hantz Financial Services, Inc. - 32 - Firm Brochure  Our Representatives Most of our representatives are registered or licensed to sell one or more financial prod- ucts and services, including securities, insurance, and residential mortgages through our firm or one of our affiliates. You have no obligation to use the services of our represent- atives. Purchasing products and services through our representatives directly benefits them personally and benefits us because of the additional compensation we will receive in those transactions. Additional compensation creates potential conflicts of interests, discussed below under the section heading, “Client Referrals and Other Compensation.” When acting as insurance agents, our representatives use Hantz Agency, LLC, listed above, as their insurance agency and may represent one or more insurance companies. We are not affiliated by common ownership or control with any insurance company. Other Relationships One of our directors, David Shea, is a member of Shea Law, PLLC, a general practice law firm. The law firm is not otherwise affiliated with us. If legal services are desired, the law firm can be retained for legal representation and services, including wills, trusts, estate plans, contracts, litigation, and various other legal matters. You are under no obli- gation to use this law firm for legal services as a condition of engaging us for any of our services. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING Code of Ethics We have adopted a Code of Ethics. It expresses our core fundamental values to be honest, fair, and forthright in our dealings with clients and others in the conduct of our business. Our Code of Ethics also guides our practices in giving investment advice to our clients and proprietary trading of securities for our own and related accounts. A copy of our Code of Ethics is available upon request by contacting the firm at the number stated on this brochure’s cover page. Participation or Interest in Client Transactions Our firm or our representatives may buy, sell, or hold for their personal accounts, some- times called proprietary or personal securities trading, the same securities that we may recommend to you and other clients. Based on everyone’s own personal circumstances, personal securities trading may be similar to or different than recommendations made to you. Hantz Financial Services, Inc. - 33 - Firm Brochure  Most of our securities recommendations involve widely-held, publicly traded securities, mutual funds, or similar funds that are held inside variable insurance contracts. We gen- erally do not give advice about thinly traded securities unless you happen to already hold those securities in your account. Accordingly, our investment advice and our personal securities trading have little potential to affect the price of the securities that we recom- mend. Our Code of Ethics and related policies address the potential conflicts of interest with respect to personal trading activities by our representatives. Generally, our representatives may not purchase or sell a security prior to a transaction being completed for a client’s account. We have this policy to prevent our employees from benefiting from transactions placed on behalf of a client’s account. Because these situations have the potential of raising conflicts of interest, we have established the fol- lowing trading restrictions: ● Our representatives may not use information available to them because of their employment with us to buy or sell securities for their personal portfolios, unless the information is also available to the investing pub- lic upon reasonable inquiry. A representative shall not favor his or her interests above your interests; ● We inform you that our representatives may receive sepa- rate compensation when implementing our financial plans; ● You have the unrestricted right to decline to implement any advice we render; ● You have the unrestricted right to choose any broker, dealer, or insur- ance company; ● We require our representatives to act in accordance with all applicable federal and state regulations that govern investment advisers and bro- ker- dealers; and ● A representative who violates these restrictions may be subject to disciplinary action, up to and including termination. ITEM 12: BROKERAGE PRACTICES The Custodian and Brokers We Use Your assets must be maintained in an account at a “qualified custodian,” generally a bro- ker-dealer or bank. For investment portfolio services, we generally require that our cli- ents use Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer, member SIPC, as the qualified custodian. We are independently owned and operated and Hantz Financial Services, Inc. - 34 - Firm Brochure  not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when instructed to do so. While we recommend that you use Schwab as a custodian/broker, you will decide whether to do so and open your account with Schwab by entering into an account agreement directly with them. We do not open the account for you. If you do not wish to place your assets with Schwab, we cannot manage your account. Not all advisors require their clients to use a particular broker-dealer or other custodian selected by the advisor. Even though your account is maintained at Schwab, we can still use other brokers to execute trades for your account, as described in the next paragraph. How We Select Brokers/Custodians We seek to recommend a custodian/broker who will hold your assets and execute trans- actions 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, these: ● Combination of transaction execution services along with asset cus- tody services (generally without a separate fee for custody); ● Capability to execute, clear and settle trades (buy and sell securities for your account); ● Capabilities to facilitate transfers and payments to and from ac- counts (wire transfers, check requests, bill payment, etc.); ● Breadth of investment products made available (stocks, bonds, mu- tual funds, exchange traded funds (ETFs), etc.); ● Availability of investment research and tools that assist us in mak- ing investment decisions; Quality of services; ● ● Competitiveness of the price of these services (commission rates, mar- gin interest rates, other fees, etc.) and willingness to negotiate them; Reputation, financial strength and stability of the provider; ● Their prior service to us and our other clients; and ● ● Availability of other products and services that benefit us, as dis- cussed below (see “Products and Services Available to Us from Schwab”). Hantz Financial Services, Inc. - 35 - Firm Brochure  Your Custody and Brokerage Costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. For some ac- counts, particularly those accounts at SMAs, 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 our commitment to maintain $500,000,000 of our clients’ assets in accounts at Schwab. This commitment benefits you because the overall commission rates and asset-based 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 (settled) into your Schwab ac- count. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account. Products and Services Available to Us from Schwab Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like us. They provide us and our clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically availa- ble to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Schwab’s support services are generally availa- ble on an unsolicited basis (we don’t have to request them) and at no charge to us as long as we keep a total of at least $10 million of our clients’ assets in accounts at Schwab. Here is a more detailed description of Schwab’s support services: Services that Benefit You. Schwab’s Institutional brokerage services include access to a broad range of investment products, execution of securities transac- tions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that May Not Directly Benefit You. Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administer- ing our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some sub- stantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available soft- ware and other technology that: Hantz Financial Services, Inc. - 36 - Firm Brochure  ● 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; and ● ● Assist with back-office functions, recordkeeping, and client reporting. Services that Generally Benefit Only Us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: Educational conferences and events; ● Technology, compliance, legal, and business consulting; ● ● Publications and conferences on practice management and business succession; and ● Access to employee benefits providers, human capital consult- ants and insurance providers. Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment of our per- sonnel. HFSI uses most of the Schwab institutional services that are discussed above. 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 we keep a total of at least $10 million of client assets in accounts at Schwab. Beyond that, these services are not contingent upon us committing any specific amount of business to Schwab trading commissions 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 potential conflict of interest. We believe, however, that Hantz Financial Services, Inc. - 37 - Firm Brochure  our selection of Schwab as custodian and broker is in the best interest of our clients. It is primarily supported by the scope, quality and price of Schwab’s services (based on the factors discussed above – see “How We Select Brokers/Custodians”) and not Schwab’s services that benefit only us. We have well in excess of the $10 million in minimum client assets under management, and do not believe that maintaining at least $10 million of those assets at Schwab in order to avoid paying Schwab quarterly service fees presents a material conflict of interest. See also, Item 14 below, “Client Referrals and Other Compensation.” Aggregation of Orders We have adopted a trade allocation policy to govern how we aggregate orders for securi- ties transactions on a portfolio basis. In doing so, we strive to treat each client fairly and will not favor one client over another client. Each account that participates in an aggre- gated order will participate at the average share price for all transactions ordered by us in that security on a given business day. If an aggregated order is not filled in its entirety, it may be allocated among participating accounts on a pro rata basis. However, if the partial fill is determined to be inappropriate for an account such that the number of shares for a particular account would be too few to warrant the investment or result in partial shares, then the shares will not be allocated to that account. If the security is so thinly traded that we are unable to obtain sufficient shares for all clients, it is possible that the entire trade would be busted. We will not aggregate trades for your accounts if you have placed restrictions on your accounts or when your account is subject to customized management. Thus, if you place restrictions on your account, we may not be able to aggregate your trades with that of our other clients. Trade Error Policy We have the responsibility to effect orders correctly, promptly and in the best interests of our clients. We have established an error correction policy, to identify and correct any errors as promptly as possible without disadvantaging you or benefiting us in any way. We have defined a “trade error” to mean when we have purchased or sold a financial instrument for a client account and that action is then determined to have been a mistake and the error results in a financial gain or loss for the client. Examples of errors may include: ● Purchases or sales of an incorrect or unintended security or number of shares of a security for a client account; ● Purchases or sales of securities for the incorrect or unintended cli- ent account; Hantz Financial Services, Inc. - 38 - Firm Brochure  ● Purchases or sales of securities that are not authorized by the cli- ent’s investment guidelines or applicable law or regulations (e.g., prohibited transaction under ERISA); ● Purchase or sale transpositions (where an intended purchase is entered as a sale, or vice versa); and Trade misallocations. ● If the error is our responsibility, your transaction will be corrected and we will reimburse you for any loss resulting from an inaccurate or erroneous order. If your account is cus- todied at Schwab, Schwab will reimburse you for any loss less than $100. If a trade error occurs and it results in a gain, the gain will remain in your account unless the same error involved other client account(s) that should have received the gain or it is not permissible for you to retain the gain. If the gain does not remain in your account and Schwab is the custodian, Schwab will donate the amount of any gain of $100 or over to charity. Schwab will maintain the loss or gain (if such gain is not retained in your account) if it is under $100 to minimize and offset its administrative time and expense. Generally, if related trade errors result in both gains and losses in your account, they may be netted. Brokerage Practices related to Our Financial Planning Services Exclusive of Invest- ment Management Services We are a registered broker-dealer. Most of our representatives are registered through us to handle securities brokerage transactions. Accordingly, we recommend our own bro- kerage services if you choose to implement our recommendations through the purchase or sale of any securities. Commissions, 12b-1 fees, and other compensation received from the implementation of our recommendations is in addition to our compensation from the financial planning and consulting fees described above. You are never obligated to use our firm, our affiliates, or our representatives to implement our financial planning recommendations. Securities brokerage services are available from other sources at a lower cost; however, discount brokerage firms generally do not provide investment advice or other customer services that we can provide you. ITEM 13: REVIEW OF ACCOUNTS Investment Management Services Reviews: While we continually monitor the underlying securities within our cli- ents’ accounts, our Asset Management Team reviews them at least quarterly on either a random or targeted basis. We review each client’s account in the context of your stated investment objectives and guidelines. More frequent reviews may Hantz Financial Services, Inc. - 39 - Firm Brochure  be triggered by material changes in variables such as changes in your individual circumstances, the market, as well as the political or economic environment. These accounts are reviewed by members of our Asset Management Team. Please note that if you have not engaged us for financial planning, any brokerage account you may hold is not subject to mandatory review. Reports: In addition to the monthly statements and confirmations of transactions that you receive from your custodian broker-dealer, we may provide you with quarterly reports. These reports summarize your portfolio position, asset alloca- tion and investment performance information on your total portfolio, as well as performance information on each security in your account. We encourage per- sonal meetings with you at least annually. When available, reports may be deliv- ered to you via email upon request. Qualified Retirement Plans Reviews: If we provide qualified retirement plan advisory services, we will re- view your Investment Policy Statement (IPS) whenever you advise us of a change in circumstances regarding the needs of the plan. We will also review the invest- ment options of the plan according to the agreed upon time intervals established in the IPS. Such reviews will generally occur annually. These accounts are re- viewed by the Retirement Services Team at the time of the account opening and, on a random or targeted basis. Reports: We will provide reports to Qualified Retirement Plan clients based on the terms set forth in their Investment Policy Statement (IPS). Selection and Monitoring of SMAs Reviews: These client accounts should refer to the independent registered invest- ment adviser’s Firm Brochure (or other disclosure document used in lieu of the brochure) for information regarding the nature and frequency of reviews provided by that independent registered investment adviser. Our Asset Management Team will provide reviews as contracted for at the inception of the advisory relationship. Reports: These clients should refer to the independent registered investment ad- viser’s Firm Brochure (or other disclosure document used in lieu of the brochure) for information regarding the nature and frequency of reports provided by that independent registered investment adviser. Our Asset Management Team may provide these client accounts with reports as contracted for at the inception of the advisory relationship. Hantz Financial Services, Inc. - 40 - Firm Brochure  Financial Planning and Consulting Services Reviews: The frequency of our reviews of clients’ accounts varies depending on your desired service level. Accordingly, you can specify the frequency of our reviews in your Financial Planning and Consulting Services Agreement. Reports: We provide a financial plan that organizes and reports on the infor- mation you provide us. The Premier Planning Service and Premier Business Planning Services may also include deliverables as specified in the Financial Planning and Consulting Services Agreement. Meetings. We will conduct client meetings on at least an annual basis if you re- new your Financial Planning and Consulting Services Agreement. More frequent reviews may be requested or may be triggered by material changes in your cir- cumstances, or material changes in the market, political, or economic environ- ment. Please promptly tell us when circumstances affecting your financial condi- tion change. Account Statements If you purchase investments, you will also receive periodic reports from the custodian for your accounts such as a clearing broker-dealer, investment company, or insurance com- pany. Mutual funds, insurance companies, and banks may serve as a custodian for one or more of your accounts and they typically send account statements to you. It is always important that you promptly review your custodian’s account statements and promptly ask your representative if you have any questions or concerns. We do not provide custodial services. We are an introducing broker-dealer for Hilltop Securities, Inc., a clearing firm. Hilltop Securities, Inc. carries our clients’ accounts. Bro- kerage account statements are provided by Hilltop Securities, Inc. We are not responsible for custodians’ services or the accuracy of their periodic account statements. Like you, we rely upon their statements and reporting for accurate infor- mation. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors that have their clients maintain accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described above (see “Item 12 Brokerage Practices”). The availability to us of Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. Hantz Financial Services, Inc. - 41 - Firm Brochure  Our financial planning recommendations may include the purchase of products or services of- fered through our firm, our affiliates, and our representatives. You are under no obligation to purchase any recommended product or service. If you elect to implement any of our recom- mendations, we will receive commissions and other fees (e.g. marketing fees) in connection with purchases made using our firm, our affiliates, and our representatives. Fees charged for our financial planning services do not include additional compensation that may be earned by our firm, our affiliates, and our representatives. We believe that having access to a variety of services, products and providers presents us with an opportunity to offer you what we consider to be the “best of breed” because we do not create proprietary investment or insurance products. It is industry practice for broker-dealers to have marketing agreements with various product suppliers (e.g. mutual funds, annuity and insurance companies, limited partnerships). Marketing agreements generally provide for the payment of marketing fees to us in addition to stated brokerage commissions and charges. These arrange- ments are sometimes referred to as “preferred supplier” relationships. These fees are paid by the sponsoring company in part to help defray the cost incurred by us for marketing and training related to the product. These marketing fees, paid to the firm, result in conflicts of interest. However, we seek to mitigate these conflicts by having our compliance department perform suit- ability reviews of client accounts and by training our representatives to put client interests first and to match the benefits and features of investment products to individual client needs without regard to our “preferred supplier” relationships. You should also understand that this additional compensation does not directly increase your expenses to invest in these products. Please see our Disclosure of Possible Conflicts of Interest for additional information about the preferred supplier compensation we receive. We may refer you to one or more of our affiliates, and they may refer clients to us for our financial planning, securities, and mortgage brokerage services. We do not pay them for referrals to us, and they do not pay us for referrals to them; however, when you purchase products or services from or through our affiliates, our firm and our introducing representatives also benefit from the additional compensation earned on your transactions. Please review the disclosures in this bro- chure under the section heading, “Other Financial Industry Activities and Affiliations” for addi- tional information about our affiliates and representatives. Our representatives who are additionally employed as a registered representative, licensed insur- ance agent, or mortgage broker are able to implement our recommended securities, insurance, or mortgage transactions for you for additional fees and charges described above. Registered repre- sentatives and insurance agents who handle these transactions will receive additional compensa- tion. Additional compensation includes, but is not limited to various kinds of marketing materials and promotions such as pens, pencils, cookies, candy, notepads, caps, clothing, meals, golf outings, event and seminar sponsorships, and tickets to various concerts and sporting events. This com- pensation is not based on a written agreement or sales performance, but is provided at the dis- cretion of the product company or its representatives. Hantz Financial Services, Inc. - 42 - Firm Brochure  Our firm and our representatives may, from time to time, receive incentive awards, such as trips, for the recommendation/introduction of investment products, or other financial planning prod- ucts. However, our representatives are required to report such compensation in their gift and gratuity log and on the monthly compliance report. The gift and gratuity log is monitored by our compliance department through its written policies and procedures. The receipt of these incen- tives may create the potential or appearance of a conflict of interest for us or our representatives regarding our recommendations. As described in Item 4, Advisory Business, HFSI has engaged the services of a third-party, on- line TAMP, SMArtX Advisory Solutions, LLC (“SMArtX”), to provide trading-related services for our Third-Party SMA Managers Program. SMArtX is a wholly owned subsidiary of SMArtX Technology Solutions Inc., West Palm Beach, Florida 33401 (“SMArtX Parent”), an unaffiliated privately owned technology company. Hantz Group, Inc. and an HFSI affiliate, which includes several of our firm’s representatives and associated persons, hold a minority ownership interest in SMArtX Technology Solutions, LLC., and, in their capacities as its shareholders, would re- ceive as compensation such dividends and distributions if, as, and when declared by its board of directors from time to time. Hantz Financial Services, Inc. has entered into a Marketing Agreement with Future Capital, Inc., to offer retirement management and investment advisory products and services to Hantz clients. Under the agreement, Future Capital engages Hantz to market the Future Capital Services and to refer Hantz’s current and prospective clients to Future Capital. Hantz is not a current client of Future Capital, but rather an independent marketing agent (or “promoter”) who is soliciting on behalf of Future Capital pursuant to a written marketing agreement. Future Capital shall charge each Referred Client an advisory fee of 42 basis points, subject to an annual maximum of $7,500.00 per client account. During the Term we and Future Capital have entered into, Future Capital shall pay Hantz 47.62% of Fee Revenue on assets managed for Referred Clients. This creates a conflict of interest because we have an incentive to recommend Future Capital’s ser- vices to you in order to increase the compensation paid to us. Furthermore, Hantz Group, Inc., Hantz Financial Services, Inc.’s parent company, issued a convertible note to ProNvest Inc., do- ing business as Future Capital, in May 2025. You are under no obligation to use Future Capital as a condition of engaging us for our services. Information on Future Capital can be found at https://adviserinfo.sec.gov/firm/summary/119081. As described in Item 8, Methods of Analysis, Investment Strategies, and Risk of Loss, Hantz Fi- nancial Services, Inc. and its affiliates have begun utilizing Photon Insights, Inc., a generative artificial intelligence tool, to assist in our aggregation and analysis of client data. Hantz Group, Inc., Hantz Financial Services, Inc.’s parent company, issued a loan to Photon Insights, Inc. in July 2025. Furthermore, Hantz Group, Inc. and some of our Registered Persons have an owner- ship interest in Photon Insights, Inc. Credit Union One Hantz Credit Union, a division of Credit Union ONE (CUONE), offers its members a wide range of financial products and services, including without limitation, member loans, mortgages, and various deposit products. A joint marketing agreement is in place with Credit Union ONE to offer Hantz Financial Services, Inc. - 43 - Firm Brochure  these available products to our clients, if desired. We will receive compensation from Credit Un- ion ONE for making referrals. Additional compensation creates potential conflicts of interest. You are under no obligation to use Hantz Credit Union, a subsidiary of Credit Union ONE, for banking services as a condition of engaging us for any of our services. ITEM 15: CUSTODY We do not have custody of any client accounts. Your custodian will provide you with account statements at least quarterly. We urge you to carefully review such statements and compare these official custodial records to any account statements or other reports that we may provide to you as described in above in, “Item 13 Review of Accounts.” Our advisor reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodolo- gies of certain securities. As a broker-dealer we may handle your individual funds or securities in purchasing or selling investments, insurance, or other financial products and services. However, we do not act as an account custodian. We promptly transmit funds or securities to the account custodian. We are an introducing broker-dealer. If you open a securities brokerage account through us, it will be held at our clearing brokerage firm, Hilltop Securities, Inc. If you open a brokerage account with our firm, you will receive periodic statements from Hilltop Securities. We urge you to carefully review those statements and compare that information to the information we may provide to you about your account. Please promptly review and ask any questions about your account statements. Hantz Agency, LLC, a related person, has limited, temporary custody of customer funds in the payment of insurance premiums to the insurance company (or insurer). Hantz Alternatives Management Company, LLC, a related person, has custody of customer funds for the purpose of investing in the feeder funds. ITEM 16: INVESTMENT DISCRETION Our Investment Management Services We generally receive limited discretionary authority in writing from clients at the outset of an advisory relationship in the Investment Advisory Agreement. If you choose to do so, limited discretionary authority grants us the ability to determine, without obtaining your specific con- sent, the securities to be bought or sold for your portfolio and the amount of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with your stated investment objectives for the account and by considering the size of your ac- count and your risk tolerance. This means that we will rebalance your accounts as needed, based upon the asset allocation model you agreed to when you engaged our investment services. We will not seek your consent prior to each rebalancing. However, we will not take discretion in Hantz Financial Services, Inc. - 44 - Firm Brochure  changing the asset allocation of your portfolio that you have agreed to unless you subsequently authorize us to do so in writing. SMA Services As applicable by your engagement, Third-Party SMA Managers and the TAMP will also hold and exercise discretionary authority in writing from you at the time of engaging their services. This authorization will be set out in the Third-Party SMA Manager’s client agreement. Our discretion is limited to “managing the managers”; that is, in our discretion we can change the Third-Party SMA Manager with respect to various investment strategies. But with respect to specific investment transactions, it is the SMA and the TAMP (and not HFSI or your representative) that holds the exclusive authority to purchase and sell secu- rities on a discretionary basis according to the investment objective you choose. Please see Item 4, Advisory Services, for an explanation of our Third-Party SMA Manag- ers Program, covered services, and the discretionary authority that is given by you to per- form these services. Our Financial Planning Services You may also give us, in writing, instructions that guide, limit, or restrict our investment recommendations. We do not implement any of our recommendations or portfolio strat- egies without your prior approval of each specific transaction, consistent with any limi- tations or restrictions you may have given us. ITEM 17: VOTING CLIENT SECURITIES We will not vote proxies for the election of corporate directors or other corporate actions de- scribed in companies’ proxy statements. If you have questions about those matters, please do not hesitate to ask us. Typically, your account custodian will forward proxies and proxy state- ments to your address of record or to your designee. ITEM 18: FINANCIAL INFORMATION While we require the prepayment of our financial planning and consulting fees as described above, we perform our services within six months of our initial engagement. We do not require or solicit prepayment of more than $1,320 in fees, per client, six months or more in advance. As described above under the heading, “Custody,” we have temporary custody of your funds or se- curities when handling some brokerage transactions that you request but we do not have on- go- ing or permanent discretionary authority or custody of your funds or securities. Hantz Financial Services, Inc. - 45 - Firm Brochure  Additionally, we have no financial condition that impairs our ability to meet our contractual and fiduciary commitments to you. We have not been the subject of any bankruptcy proceeding. Hantz Financial Services, Inc. - 46 - Firm Brochure