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Hapanowicz & Associates Financial Services, Inc.
Firm Brochure (Form ADV Part 2A)
January 2026
This brochure provides information about the qualifications and business practices of Hapanowicz &
Associates Financial Services, Inc. If you have any questions about the contents of this brochure, please
contact us at (412) 261-5966 or reh@hapfinancial.com. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission (SEC) or by any state
securities authority. Registration does not imply a certain level of skill or training.
Additional information about our investment advisory business is also available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2 – Material Changes
Since filing our last annual amendment in February 2025, the following changes have been made to this
disclosure brochure:
• The investment advisor representatives of the firm have ended their relationship as registered
representatives of LPL Financial, LLC. This change resulted in an update to Item 10 - Other
Financial Industry Activities and Affiliations.
We will continue to ensure that you receive a summary of material changes, if any, to this and
subsequent disclosure brochures within 120 days after our fiscal year ends. Our fiscal year ends on
December 31st, so you will receive the summary of material changes, if any, no later than April 30 each
year. At that time, we will also offer a copy of the most current disclosure brochure. We may also provide
other ongoing disclosure information about material changes as necessary.
Hapanowicz & Associates Financial Services, Inc.
Foster Plaza 6, 681 Andersen Drive, Suite 100 | Pittsburgh, PA 15220 | 412.261.5966
www.hapfinancial.com
Item 3 – Table of Contents
Item 2 – Material Changes .......................................................................................................................... 1
Item 3 – Table of Contents ......................................................................................................................... 2
Item 4 – Advisory Business ....................................................................................................................... 3
Description of Advisory Firm ..................................................................................................................... 3
General Description of Primary Advisory Services ................................................................................... 3
Hapanowicz Strategic Wealth Investment Management (Hapanowicz SWIM) ........................................ 3
Participation in Wrap Fee Programs ......................................................................................................... 5
Assets Under Management....................................................................................................................... 6
Item 5 – Fees and Compensation .............................................................................................................. 6
Financial Planning ..................................................................................................................................... 6
Hapanowicz SWIM (Strategic Wealth Investment Management) Program .............................................. 7
Retirement Plan Consulting Services ....................................................................................................... 8
Compensation for the Sale of Securities or Other Investment Products .. Error! Bookmark not defined.
Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................... 9
Item 7 – Types of Clients .......................................................................................................................... 10
Minimum Investment Amount Guidelines ............................................................................................... 10
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................. 10
Item 9 – Disciplinary Information ............................................................................................................ 13
Item 10 – Other Financial Industry Activities and Affiliations .............................................................. 13
Arrangement with LPL Financial ........................................................... Error! Bookmark not defined.
Insurance Sales Activities ....................................................................................................................... 13
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ...................... 14
Code of Ethics Summary ........................................................................................................................ 14
Affiliate and Employee Personal Securities Transactions Disclosure .................................................... 14
Item 12 – Brokerage Practices ................................................................................................................. 14
Item 13 – Review of Accounts ................................................................................................................. 15
Item 14 – Client Referrals and Other Compensation ............................................................................. 15
Item 15 – Custody ..................................................................................................................................... 16
Item 16 – Investment Discretion .............................................................................................................. 17
Item 17 – Voting Client Securities ........................................................................................................... 17
Item 18 – Financial Information ............................................................................................................... 18
Business Continuity Plan ......................................................................................................................... 18
CUSTOMER PRIVACY NOTICE ................................................................................................................ 19
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Item 4 – Advisory Business
Description of Advisory Firm
Hapanowicz & Associates Financial Services, Inc. is a registered investment advisor with the U.S.
Securities and Exchange Commission and is properly approved or exempt from registration in the states
where we conduct business. Hapanowicz & Associates Financial Services, Inc. performs its investment
advisory activities under the names Hapanowicz Financial and Hapanowicz. Our firm is a Corporation
formed under the laws of the State of Pennsylvania.
• Hapanowicz & Associates Financial Services, Inc. is 100% owned by Robert Hapanowicz.
• Our firm has been registered as an investment advisor since May 2011.
• We provide fee-based investment advisory services through Hapanowicz & Associates Financial
Services, Inc. The nature and extent of the specific services provided to clients, including you,
depends upon each client’s financial status, objectives and needs, time horizons, concerns,
expectations and risk tolerance.
• When providing advisory services, we are able to use various programs sponsored by LPL
Financial, an investment advisor registered with the SEC.
General Description of Primary Advisory Services
Financial Planning Services – We provide advisory services in the form of financial planning services.
Financial planning services do not involve the active management of client accounts, but instead focus on
a client’s overall financial situation. We provide financial analysis and financial planning services
consistent with your current financial and tax status, financial goals, investment attitudes and risk/reward
parameters.
Financial planning can be described as helping individuals determine and set their long-term financial
goals through investments, tax planning, asset allocation, risk management, retirement planning, and
other areas. The role of a financial planner is to find ways to help the client understand his/her overall
financial situation and help the client set financial objectives.
Asset Management Services – We provide discretionary asset management advisory services wherein
we provide clients with continuous and on-going supervision over their accounts. We will first have
conversations with you to gain a complete understanding of your financial objectives, time frame, risk
tolerance, cash flow needs and any special circumstances. We will then help you select an investment
objective, which will guide us in managing your account. We will then construct your diversified portfolio
using a variety of investment vehicles typically including, but not limited to, institutional no-load and load-
waived open end mutual funds, exchange traded funds and individual equities.
Hapanowicz Strategic Wealth Investment Management (Hapanowicz SWIM)
Asset management services are provided via LPL Financial’s SWM (Strategic Wealth Management)
platform. Through this service, our firm offers a customized and individualized investment program for
clients. A specific asset allocation strategy is crafted to focus on the specific client’s goals and objectives.
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Clients will be required to complete a Confidential Profile & Questionnaire in order to help define the risk
tolerance and investment objective of the client.
Hapanowicz Strategic Wealth Investment Management (SWIM) accounts are established at LPL Financial
(referred to as “LPL Financial” or “LPL” throughout) in its capacity as a registered broker/dealer, member
Financial Industry Regulatory Authority (FINRA) and Securities Investors Protection Corporation (SIPC).
Clearing, custody and other brokerage services are provided by LPL Financial for accounts established
through the Hapanowicz SWIM program. Therefore, clients may be required to establish a brokerage
account(s) through LPL Financial’s SWM platform. Separate accounts are maintained for each client.
Each client retains all rights of ownership of their accounts (e. g. right to withdraw securities or cash,
exercise or delegate proxy voting, and receive transaction confirmations).
Within Hapanowicz SWIM accounts, clients authorize Hapanowicz to purchase and sell on a discretionary
basis, portfolios consisting of securities and investments. Hapanowicz may limit its discretion with respect
to the client account and the securities eligible to be purchased for the client account.
Prior to engaging Hapanowicz to provide investment management services, the client will be required to
enter into a formal investment advisory agreement with Hapanowicz setting forth the terms and
conditions, including the amount of investment advisory fees, under which Hapanowicz shall manage the
client’s assets, and a separate custodial/clearing agreement with LPL Financial.
Retirement Plan Management and Consulting Services - Hapanowicz offers retirement plan
management and consulting services to retirement plan sponsors and to individual participants in
retirement plans. For a corporate sponsor of a retirement plan, our retirement plan consulting services
may include, but are not limited to, the following services:
Fiduciary Consulting Services
Hapanowicz provides the following Fiduciary Retirement Plan Consulting Services:
• Qualified Plan Development. Hapanowicz will assist you with the establishment of a qualified plan
by working with you and a selected Third-Party Administrator. If you have not already selected a
Third-Party Administrator, we shall assist you with the review and selection of a Third-Party
Administrator for the Plan.
•
Investment Policy Statement. Hapanowicz will help you develop an investment policy statement.
The investment policy statement establishes the investment policies and objectives for the Plan.
You will have the ultimate responsibility and authority to establish such policies and objectives
and to adopt and amend the investment policy statement.
•
Investment Selection Services. Hapanowicz will provide you with recommendations for
investment options within your plan.
• Due Diligence Review. Upon request, Hapanowicz will provide you with periodic due diligence
reviews of the Plan, the Plan’s fees and expenses, and the Plan’s portfolio managers.
•
Investment Monitoring. Hapanowicz will assist in monitoring investment options, consistency of
fund management and conformation to the guidelines set forth in the investment policy statement
and Hapanowicz will make recommendations to maintain or remove and replace investment
options.
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• Participant Advice. Upon request, Hapanowicz will provide one-on-one advice to Plan
participants.
• Fiduciary File Set-up. Hapanowicz will help you establish a “fiduciary file” for the Plan which
contains trust documents, custodial/brokerage statements, services agreements with investment
management vendors, the investment policy statement, investment committee minutes, asset
allocation/asset liability studies, due diligence fields on funds/money managers and monitoring
procedures for funds and/or money managers.
Non-Fiduciary Services
Hapanowicz provides clients with the following Non-Fiduciary Retirement Plan Consulting Services:
• Participant Educational Presentations. Hapanowicz will provide educational presentations for
Plan participants. Presentations to Plan participants are informational in nature and intended
to provide an overview of the Plan and the Plan’s investment selections. Educational
presentations will not take into account the individual circumstances of each participant and
individual recommendations will not be provided unless otherwise agreed upon.
• Participant Enrollment. Hapanowicz will assist you with group enrollment meetings designed
to increase retirement plan participation among employees and investment and financial
understanding by the employees.
The exact suite of services provided to a client will be listed and detailed in the Qualified Retirement Plan
Consulting Agreement.
In the event a client contracts with Hapanowicz to provide one-on-one consulting services to plan
participants, such services are consultative in nature and do not involve Hapanowicz implementing
recommendations in individual participant accounts. It will be the responsibility of each participant to
implement changes in the participant’s individual accounts.
We may also meet with individual participants to discuss their specific investment risk tolerance,
investment time frame and investment selections. For clients with self-directed 401K Plan Accounts all
recommendations of investment options and portfolios will be submitted to the client for the client’s
ultimate approval or rejection. Therefore, it is always the client’s responsibility to accept investment
recommendations of Hapanowicz and then physically make changes to the client’s account.
Participation in Wrap Fee Programs
We offer asset management services through both wrap fee programs and non-wrap fee programs. A
wrap fee program is defined as any advisory program under which a specified fee or fees not based
directly upon transactions in a client’s account is charged for investment advisory services (which may
include portfolio management or advice concerning the selection of other investment advisers) and the
execution of client transactions. Whenever a fee is charged to a client for services described in this
brochure (whether wrap fee or non-wrap fee), we will receive all or a portion of the fee charged.
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Assets Under Management
We manage and administer approximately $622,317,239 as of December 31, 2025. Of this total,
$519,537,574 are managed by Hapanowicz & Associates Financial Services, Inc. on a discretionary
basis, and $102,779,665 are Qualified Retirement Plans managed on a non-discretionary basis.
Item 5 – Fees and Compensation
In addition to the information provided in Item 4 – Advisory Business, this section provides details
regarding our services along with descriptions of each service’s fees and compensation arrangements.
Immediate family members of Hapanowicz & Associates Financial Services, Inc.’s associated persons
may be offered a discounted fee. On occasion and at our complete discretion, discounts may be offered
to other clients as well.
Financial Planning
The fees for these services are generally based on the time required to perform the services and are
billed at a rate based upon the complexity of the client’s financial plan, subject to increases or decreased
upon further review. Hapanowicz & Associates Financial Services, Inc. also offers consultation services
on any topic of interest to the client. Consultation services can include general non-securities advice on
topics such as tax planning, estate planning and business planning. The fees for these financial services
are also included in the rate described above. Hapanowicz does not provide legal or tax advice, however
we do work well with your tax and legal advisors.
An estimate of the time required will be made before work begins, and a maximum fee will be indicated
on the advisory agreement signed by the client. Fees for the above services are due and payable within
30 days after the services are performed.
Financial planning services automatically terminate upon presentation of the plan to the client or upon
completion of the consultation. Either party can also terminate the advisory agreement before then by
providing written notice to the other party. Termination will be effective upon receipt of notice. If
terminated within five business days of signing the advisory agreement, services are terminated without
penalty. If the agreement is terminated after five business days but prior to completion of services, at the
option of Hapanowicz & Associates Financial Services, Inc.’s associated persons, clients may be
responsible for the time expended and expenses disbursed prior to receipt of the termination notice. In
this case, Hapanowicz & Associates Financial Services, Inc. will provide clients with a statement detailing
the time and expenses due.
Other Fee Terms for Financial Planning & Consulting Services
You may pay the investment advisory fees owed for the financial planning services by submitting
payment directly (for example, by check) or having the fee deducted from an existing investment account.
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If you elect to pay by automatic deduction from an existing investment account, you will provide written
authorization to Hapanowicz & Associates Financial Services, Inc. for such charge.
You should notify Hapanowicz & Associates Financial Services, Inc. within ten (10) days of receipt of an
invoice if you have questions about or dispute any billing entry.
As a part of our Financial Planning and Financial Consulting Services Hapanowicz has entered into
agreements with Accountants and Attorneys to provide support to our financial planning and consulting
services. Hapanowicz will be responsible for the payment of the fees for the services of all professionals
we engage and you will not be required to reimburse us for such payments. Clients may decide to
engage the Accountant or Attorney utilized by Hapanowicz separate from our planning or consulting
services. In these instances, you will be responsible for the payment of the fees for the services of these
professionals.
Hapanowicz SWIM (Strategic Wealth Investment Management) Program
The annual investment advisory fee charged shall vary up to 2.0% of the assets held in the account and
is determined by the market value of the account, asset types, the client’s financial situation and trading
activity, and is negotiable with the client. The annual fee shall be divided and payable quarterly in
advance through a direct debit in the client account. LPL Financial is responsible for calculating and
debiting all fees from client accounts. Clients must provide LPL Financial written authorization to debit
advisory fees from their accounts and pay such fees to Hapanowicz. Fees are based on the account's
asset value as of the last business day of the prior calendar quarter. Fees for accounts opened at any
time other than the beginning of a quarter will be prorated based on the number of days remaining in the
initial quarter. Advisory fees for the current calendar quarter are based on the Account's asset value as of
the last business day of the prior calendar quarter. For billing purposes, the market value used by Advisor
in calculating the quarterly advisory fee will vary from the market value reported in the account statements
sent by LPL due to the timing differences associated with the receipt of dividends and interest. Fees for
Accounts opened at any time other than the beginning of a quarter will be based on the value of assets
when the Account is opened and will be prorated based on the number of days remaining in the initial
quarter. In addition, any additions to or withdrawals from the Account during the quarter will be prorated,
based on the number of days remaining in the quarter, for the purpose of calculating the advisory fee.
The minimum household account size is $1,000,000 with the exception of $300,000 for family members
of existing clients. Exceptions to these minimums may be granted at the discretion of the firm.
Clients may open a Hapanowicz SWIM1 or SWIM2 account. In a Hapanowicz SWIM1 account, in
addition to the investment advisory fee, the client will pay certain transaction charges to defray the costs
associated with trade execution. These costs are set out in the LPL Strategic Wealth Management
platform brokerage account and application agreement. In the Hapanowicz SWIM2 account, the client
does not pay transaction charges associated with trade execution. However, the total advisory fee
charged by the firm for SWIM2 accounts is higher than the advisory fee charged for Hapanowicz SWIM1
accounts. Higher fees for Hapanowicz SWIM2 accounts are charged by Hapanowicz to help absorb the
transaction costs.
Clients may incur certain charges imposed by third parties other than Hapanowicz in connection with
investments made through the account, including but not limited to, 12b-1 fees and surrender charges
and IRA and qualified retirement plan fees. Management fees charged by Hapanowicz (which include
transaction and execution fees charged by LPL Financial for Hapanowicz SWIM2 accounts) are separate
and distinct from the fees and expenses charged by investment company securities that may be
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recommended to clients. A description of these fees and expenses are available in each investment
company security’s prospectus. Hapanowicz and our investment advisor representatives will not receive
any portion of the 12b-1 fees or other commissions charged to the client. However, such commissions
will be retained by LPL Financial. These commissions may include 12b-1 fees, surrender charges, and
IRA and qualified retirement plan fees.
Hapanowicz SWIM1 / SWIM2 accounts may cost the client more or less than if the assets were held in a
traditional brokerage account. In a brokerage account, the client is charged commissions for each
transaction, and the representative has no duty to provide ongoing advice with respect to the account. If
the client plans to follow a buy and hold investment strategy for the account or does not wish to purchase
ongoing investment advice or management services, the client should consider opening a brokerage
account rather than a Hapanowicz SWIM1 or SWIM2 account.
Either party may terminate the agreement for services at any time. If services are terminated within five
(5) business days of executing the agreement, services will be terminated without penalty and a full
refund of all fees paid in advance will be provided. If services are terminated after the initial five-day
period, Hapanowicz shall provide the client with a pro-rated refund of fees paid in advance. The refund
will be based on the number of days service was actually provided during the final billing period.
Termination shall be effective from the time the other party receives written notification or such other time
as may be mutually agreed upon, subject to the settlement of transactions in progress and the final refund
of advisory fees. There will be no penalty charge upon termination.
Retirement Plan Consulting Services
For retirement plan sponsors, the Plan will be charged an annual fee of up to 1% of the amount of Plan
assets. This fee is negotiable based upon the complexity of the plan, the size of the plan assets, the
actual services requested, the representative providing the services and the potential for additional
deposits.
For individual participants, we will also charge an annual fee of up to 1% of the participant’s account
value. Fees are negotiable based upon the actual services requested and the complexity of the
participant’s situation.
For retirement plan sponsors and participants, fees may be billed in advance (at the start of the billing
period) or in arrears. Fees will be billed on a quarterly calendar basis and will be calculated based on the
fair market value of your account as of the last business day of the previous billing period. Fees are
prorated (based on the number of days service is provided during the initial billing period) for your
account opened at any time other than the beginning of the billing period. Retirement plan sponsors may
also elect to pay all or a portion of fees for the individualized services provided by us to the plan
participants.
Fees will be directly deducted from clients’ accounts. Clients are required to provide the custodian with
written authorization to deduct the fees from the account and pay the fees to Hapanowicz. We will
provide the custodian with a fee notification statement.
Either party may terminate services by providing written notice of termination to the other party. If
services are terminated within five business days of signing the client agreement, services are terminated
without penalty. Any prepaid but unearned fees are promptly refunded to the client at the effective date of
termination.
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Hapanowicz does not reasonably expect to receive any other compensation, direct or indirect, for its
Services. If we receive any other compensation for such services, we will (i) offset that compensation
against our stated fees, and (ii) will disclose the amount of such compensation, the services rendered for
such compensation and the payer of such compensation to you.
Vanguard - Hapanowicz has entered into an agreement with Vanguard, Inc. to utilize their Vanguard
Retirement Plan Access 401(K) platform. Through this platform, Hapanowicz clients may contract for
401K plan record keeping and reporting services and incur a fee as described in the Vanguard
Retirement Plan Recordkeeping Services Agreement. Hapanowicz will not receive any portion of the
recordkeeping fees charged to the client. The fees charged by Vanguard may be more or less than fees
charged by other vendors providing similar services.
Empower Retirement – Hapanowicz has entered into an agreement with Empower Retirement to utilize
their Empower Retirement Recordkeeping platform. Through this platform, Hapanowicz clients may
contract for 401(k) plan recordkeeping and reporting services and incur a fee as described in the
Empower Retirement Service Agreement Contract. Hapanowicz will not receive any portion of the
recordkeeping fees charged to the client. The fees charged by Empower Retirement may be more or less
than fees charged by other vendors providing similar services.
ADP – Hapanowicz has entered into an agreement with ADP to utilize their ADP Open Fund Architecture
platform. Through this platform, Hapanowicz clients may contract for 401(k) plan recordkeeping and
reporting services and incur a fee as described in the ADP Compensation and Fee Disclosure
Agreement. Hapanowicz will not receive any portion of the recordkeeping fees charged to the client. The
fees charged by ADP may be more or less than fees charged by other vendors providing similar services.
American Funds - Hapanowicz has entered into an agreement with American Funds to utilize their
American Funds Plan Premier platform. Through this platform, Hapanowicz clients may contract for
401(k) plan recordkeeping and reporting services and incur a fee as described in the American Funds
Recordkeeping Services Agreement. Hapanowicz will not receive any portion of the recordkeeping fees
charged to the client. The fees charged by American Funds may be more or less than fees charged by
other vendors providing similar services.
Human Interest - Hapanowicz has entered into an agreement with Human Interest to utilize their Human
Interest Concierge platform. Through this platform, Hapanowicz clients may contract for 401(k) plan
recordkeeping and reporting services and incur a fee as described in the Human Interest Matrix Trust
Company Custodial Account Agreement. Hapanowicz will not receive any portion of the recordkeeping
fees charged to the client. The fees charged by Human Interest may be more or less than fees charged
by other vendors providing similar services.
Item 6 – Performance-Based Fees and Side-By-Side Management
This item is not applicable as Hapanowicz & Associates Financial Services, Inc. does not charge or
accept performance-based fees (fees based on a share of capital gains on or capital appreciation of the
assets held within a client’s account).
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Item 7 – Types of Clients
Hapanowicz & Associates Financial Services, Inc. generally provides investment advice to the following
types of clients:
Individuals
•
• High Net Worth Individuals
• Pension and profit-sharing plans
• Trusts, family partnerships, estates and charitable organizations
• Corporations and business entities other than those listed above
Minimum Investment Amount Guidelines
• Hapanowicz & Associates Financial Services, Inc. recommends a minimum investment amount of
$1,000,000 for establishing and maintaining a Hapanowicz SWIM Account. Under certain
circumstances, accounts below $1,000,000 will be considered and may be accepted at the sole
discretion of Hapanowicz & Associates Financial Services, Inc.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Hapanowicz & Associates Financial Services, Inc. evaluates the potential benefits and risks inherent
within investment categories. Investment characteristics are then matched to the client’s needs and
preferences to determine an appropriate mix of investment vehicles. Investments and mutual funds
within a particular investment category are selected. Analysis is focused on risk parameters that relate
that to the risk tolerance of each individual client. We look at volatility of portfolios, relative historic
performance, and consistency over multiple market cycles.
Hapanowicz may use the following methods of analysis in formulating investment advice:
Charting - The set of techniques used in technical analysis in which charts are used to plot price
movements, volume, settlement prices, open interest, and other indicators, in order to anticipate future
price movements. Users of these techniques, called chartists, believe that past trends in these indicators
can be used to extrapolate future trends.
Fundamental - A method of evaluating a security by attempting to measure its intrinsic value by
examining related economic, financial and other qualitative and quantitative factors. Fundamental
analysts attempt to study everything that can affect the security's value, including macroeconomic factors
(like the overall economy and industry conditions) and individually specific factors (like the financial
condition and management of companies). The end goal of performing fundamental analysis is to
produce a value that an investor can compare with the security's current price in hopes of figuring out
what sort of position to take with that security (underpriced = buy, overpriced = sell or short). This method
of security analysis is considered to be the opposite of technical analysis. Fundamental analysis is about
using real data to evaluate a security's value. Although most analysts use fundamental analysis to value
stocks, this method of valuation can be used for just about any type of security.
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Cyclical - Analyzes the investments sensitive to business cycles and whose performance is strongly tied
to the overall economy. For example, cyclical companies tend to make products or provide services that
are in lower demand during downturns in the economy and higher demand during upswings. Examples
include the automobile, steel, and housing industries. The stock price of a cyclical company will often rise
just before an economic upturn begins, and fall just before a downturn begins. Investors in cyclical stocks
try to make the largest gains by buying the stock at the bottom of a business cycle, just before a
turnaround begins.
Technical - A method of evaluating securities by analyzing statistics generated by market activity, such
as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value, but
instead use charts and other tools to identify patterns that can suggest future activity. Technical analysts
believe that the historical performance of stocks and markets are indications of future performance.
Hapanowicz & Associates Financial Services, Inc. uses the following investment strategies when
managing client assets and/or providing investment advice.
Investment strategies are designed to satisfy a hierarchy of client goals and objectives. First, a client’s
needs of short term cash flow and liquidity are considered. Appropriate investment vehicles and a cash
reserve are recommended. Second, long term growth needs combined with needs for continuing liquidity
are examined. Investments are selected which appear attractive for long term growth and are readily
convertible to cash should circumstances warrant. Once these first two needs are satisfied, emphasis is
placed on long-term investments which may or may not be liquid and which may provide tax reduction
benefits.
Model mutual fund asset allocation portfolio programs, provided by a number of institutional investment
managers and strategist, may be used when managing client assets.
The following are some of the general strategies that may be used when managing accounts.
Long term purchases. Investments held at least a year.
Short term purchases. Investments sold within a year.
Tactical asset allocation. Allows for a range of percentages in each asset class (such as Stocks = 40-
50%). These are minimum and maximum acceptable percentages that permit the investor to take
advantage of market conditions within these parameters. Thus, a minor form of market timing is possible,
since the investor can move to the higher end of the range when stocks are expected to do better and to
the lower end when the economic outlook is bleak.
Strategic asset allocation. Calls for setting target allocations and then periodically rebalancing the
portfolio back to those targets as investment returns skew the original asset allocation percentages. The
concept is akin to a “buy and hold” strategy, rather than an active trading approach. Of course, the
strategic asset allocation targets may change over time as the client’s goals and needs change and as
the time horizon for major events such as retirement and college funding grow shorter.
The Hapanowicz primary strategy is a blend of strategic and tactical. Some of the risks involved with
using this method include short term volatility to achieve longer term goals.
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The Hapanowicz primary strategy may involve the frequent trading of securities. The frequent trading of
securities may have a positive or negative impact on investment performance. Performance from active
trading can be lowered due to an increase in brokerage and other transaction costs.
Clients should understand that past performance is not indicative of future results. Therefore, current and
prospective clients (including you) should never assume that future performance of any specific
investment or investment strategy will be profitable. Investing in securities (including stocks, mutual
funds, and bonds) involves risk of loss. Further, depending on the different types of investments there
may be varying degrees of risk. Clients and prospective clients should be prepared to bear investment
loss including loss of original principal.
Because of the inherent risk of loss associated with investing, our firm is unable to represent, guarantee,
or even imply that our services and methods of analysis can or will predict future results, successfully
identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There
are certain additional risks associated when investing in securities through our investment management
program.
Market Risk – Either the stock market as a whole, or the value of an individual
company, goes down resulting in a decrease in the value of client investments.
This is also referred to as systemic risk.
Equity (stock) market risk – Common stocks are susceptible to general stock
market fluctuations and to volatile increases and decreases in value as market
confidence in and perceptions of their issuers change. If you held common stock,
or common stock equivalents, of any given issuer, you would generally be exposed
to greater risk than if you held preferred stocks and debt obligations of the issuer.
Company Risk. When investing in stock positions, there is always a certain level
of company or industry specific risk that is inherent in each investment. This is also
referred to as unsystematic risk and can be reduced through appropriate
diversification. There is the risk that the company will perform poorly or have its
value reduced based on factors specific to the company or its industry. For
example, if a company’s employees go on strike or the company receives
unfavorable media attention for its actions, the value of the company may be
reduced.
Fixed Income Risk. When investing in bonds, there is the risk that issuer will default
on the bond and be unable to make payments. Further, individuals who depend
on set amounts of periodically paid income face the risk that inflation will erode
their spending power. Fixed-income investors receive set, regular payments
that face the same inflation risk.
Options Risk. Options on securities may be subject to greater fluctuations in value
than an investment in the underlying securities. Purchasing and writing put and
call options are highly specialized activities and entail greater than ordinary
investment risks.
Exchange Traded Fund (ETF) and Mutual Fund Risk – When Hapanowicz &
Associates Financial Services, Inc. invests in an ETF or mutual fund for a client,
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fund’s operating expenses,
including
the client will bear additional expenses based on its pro rata share of the ETFs or
mutual
the potential duplication of
management fees. The risk of owning an ETF or mutual fund generally reflects
the risks of owning the underlying securities the ETF or mutual fund holds. Clients
will also incur brokerage costs when purchasing ETFs.
Management Risk – The value of your investment with our firm varies with the
success and failure of our investment strategies, research, analysis and
determination of portfolio securities. If our investment strategies do not produce
the expected returns, the value of the investment will decrease.
Item 9 – Disciplinary Information
This item is not applicable because there are no legal or disciplinary events that would be considered
material to your evaluation of Hapanowicz business or integrity.
Item 10 – Other Financial Industry Activities and Affiliations
Hapanowicz is an independent investment advisory firm and only provides investment advisory services.
The firm is not engaged in any other business activities and offers no other services than those described
in this Disclosure Brochure.
While Hapanowicz does not sell products or services other than investment advice, our investment
advisor representatives may sell other products or provide services outside of their role with Hapanowicz.
Our investment advisor representatives concentrate the majority of their efforts toward sales of
investments and investment advisory services.
Insurance Sales Activities
Some investment advisor representatives are licensed to provide insurance services to clients. Insurance
products are provided to clients for personal, estate and business need to minimize clients’ exposure to
identified risks. Although clients are under no obligation to purchase insurance products recommended by
investment advisor representative in their separate capacities and insurance agents, clients often
purchase such products when needs arise. When clients of Hapanowicz purchase products generating
commissions, these are paid to the investment advisor representatives in their separate capacities as
insurance agents.
You are never obligated or required to purchase insurance products through one of our advisor
representatives licensed as insurance agents. However, when acting as an insurance agent, our advisor
representatives can help you purchase insurance products and will receive separate compensation (i.e.
insurance commissions) in addition to investment advisory fees charged by Hapanowicz. Clients that
choose to purchase insurance products though one of our advisor representatives should be aware they
will generally only recommend insurance products of those companies for whom they are sales agents
and with which they are familiar with the benefits, exclusions and other terms.
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Because our advisor representatives will receive commissions for selling insurance products, there is a
conflict of interest in that they may recommend policies to clients that do not require or need insurance.
To control for this conflict of interest and to be consistent with our firm’s fiduciary duty, our advisor
representatives strive to recommend insurance products only to those clients who need new or additional
insurance coverage.
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading
Code of Ethics Summary
We have established a Code of Ethics which all supervised persons must read and then execute an
acknowledgment agreeing that they understand and agree to comply with its terms. Our fiduciary duty to
clients is considered the core underlying principle for the Code of Ethics and represents the expected
basis for all supervised persons dealings with clients. We have the responsibility to make sure that the
interests of clients are placed ahead of our own investment interests.
All supervised persons will conduct business in an honest, ethical and fair manner. All supervised
persons will comply with all federal and state securities laws at all times. Full disclosure of all material
facts and conflicts of interest will be provided to clients prior to services being conducted. All associated
persons have a responsibility to avoid circumstances that might negatively affect or appear to affect the
associated persons’ duty of complete loyalty to their clients.
Affiliate and Employee Personal Securities Transactions Disclosure
We may buy or sell investments or have an interest or position in an investment for our personal accounts
which are also recommended to clients. As these situations may represent a conflict of interest, we have
implemented the following policies.
• Associated persons cannot prefer their own interests to that of advisory clients.
• No person employed by our firm may purchase or sell any security prior to a transaction or
transactions being implemented for an advisory account.
• Associated persons shall not buy or sell securities for their personal account(s) where their
decision is derived, in whole or in part, by information obtained as a result of his/her employment,
unless the information is also available to the investing public upon reasonable inquiry.
•
Investments we recommend to clients generally include mutual funds, ETFs, and other
investments that are publicly traded and widely available therefore limiting the risk for
manipulation.
Item 12 – Brokerage Practices
Clients wishing to implement Hapanowicz advice are free to select any broker they wish and are so
informed.
Brokerage Recommendations
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If we assist you in the implementation of any recommendations, typically LPL Financial will be used as
the broker/dealer for your account. Hapanowicz is independently owned and operated and not affiliated
with LPL Financial.
If clients wish to implement the advice of Hapanowicz, LPL will be used as the broker/dealer and/or
custodian. LPL will be the primary broker/dealer and custodian recommended due to the firm’s
relationship with LPL. Hapanowicz recommends broker/dealers and custodians that Hapanowicz feels
will provide services in a manner and at a cost that will allow the firm to meet its duty of best execution.
While there is no direct linkage between the investment advice given to clients and Hapanowicz
recommendation of LPL, economic benefits may be provided by LPL to the firm that will not be provide if
the client selects another broker/dealer or account custodian. These benefits may include: negotiated
costs for transaction implementation, a dedicated trade desk that services LPL participants exclusively, a
dedicated service group and an account services manager dedicated to the firm's accounts, access to a
real-time order matching system, electronic download of trades, balances and position information,
access, for a fee, to an electronic interface with the account custodian’s software, duplicate and batched
client statements and confirmations.
Our trading policy is to implement all client orders on an individual basis. From time to time, we do
aggregate or “block” client transactions. Considering the types of investments we hold in advisory client
accounts, we do not believe clients are hindered in any way because we trade accounts individually. This
is because we develop individualized investment strategies for clients and holdings will vary. Further, the
investments we are responsible for trading in client accounts are typically limited to mutual funds, ETFs,
and other broadly traded positions. Our strategies are primarily developed for the long-term and minor
differences in price execution are not material to our overall investment strategy.
Item 13 – Review of Accounts
Portfolio performance is reviewed weekly by our Investment Committee, that includes a team of
credentialed and experienced professionals.
You will receive monthly statements from the account custodian or clearing firm, if your account(s) have
activity during the month. If the account does not have any monthly activity, an account statement is
provided by the account custodian or clearing firm at least quarterly. Such statements will show any
activity in the account, as well as period ending position balances. You will also receive a confirmation
from the custodian or clearing firm of each purchase and sale transaction that occurs within Hapanowicz
SWIM accounts.
Item 14 – Client Referrals and Other Compensation
Upon client request, Hapanowicz may provide one or more professional referrals (i.e. attorneys, CPAs
etc.). Referrals will be carefully considered to align with each client’s needs and objectives.
Hapanowicz can enter into agreements with various referring parties (Endorsers) to refer clients to
Hapanowicz. If a referred client enters into an investment advisory agreement with Hapanowicz, a cash
referral fee can be paid to the referring party, which is based upon a percentage of the client advisory
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fees that are generated. The referral agreements between any referring party and Hapanowicz will not
result in any charges to clients in addition to the normal level of advisory fees charged.
When a client is referred to Hapanowicz by an Endorser, the Endorser will provide the client with a copy
of the Hapanowicz Disclosure Brochure as required by the Investment Advisers Act of 1940. The client
also will complete a Solicitor’s Disclosure Statement document. If the referring party is an unaffiliated
registered investment adviser firm, then the client will also receive a copy of the referring party’s Form
ADV Part 2 Disclosure Brochure. If a referred client enters into an investment advisory agreement with
Hapanowicz a referral fee is paid to the Endorser. The referral relationship will not result in clients being
charged any fees over and above the normal advisory fees charged for the advisory services provided.
The referral agreements between Hapanowicz and Endorsers are in compliance with state and federal
securities rules regarding paid endorse arrangements.
Insurance Referral Relationships:
In addition to the direct receipt of insurance related commissions discussed in Item 10 – Other Financial
Industry Activities and Affiliations Hapanowicz can receive referral fees (in the form of a portion of the
insurance commission) for recommending that our clients utilize a particular Insurance Agency. Clients
are always free to use any insurance agency they choose. Although Hapanowicz always endeavors to
put the interest of its clients ahead of its own or those of its officers, directors, or representatives
(“affiliated persons”), these arrangements could affect the judgment of the firm when recommending
products. These situations present a conflict of interest that may affect the judgment of Hapanowicz and
our associated persons.
In addition, we may from time to time receive expense reimbursement for travel and/or marketing
expenses from distributors of investment and/or insurance products. Travel expense reimbursements are
typically a result of attendance at due diligence and/or investment training events hosted by product
sponsors. Marketing expense reimbursements are typically the result of informal expense sharing
arrangements in which product sponsors may underwrite costs incurred for marketing such as client
appreciation events, advertising, publishing and seminar expenses. Although receipt of these travel and
marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor
reimbursements are typically made by those sponsors for whom sales have been made or it is anticipated
sales will be made. This creates a conflict of interest in that there is an incentive to recommend certain
products and investments based on the receipt of this compensation instead of what is the in best interest
of our clients. We attempt to control for this conflict by always basing investment decisions on the
individual needs of our clients.
Item 15 – Custody
Custody, as it applies to investment advisors, has been defined by regulators as having access or control
over client funds and/or securities. In other words, custody is not limited to physically holding client funds
and securities. If an investment advisor has the ability to access or control client funds or securities, the
investment advisor is deemed to have custody and must ensure proper procedures are implemented.
According to this definition, Hapanowicz does not have custody of client funds or securities. It should be
noted that our firm does have limited discretionary authority to transfer funds between a client’s accounts
with similar registrations held with a qualified custodian and may send funds to the client’s address of
record if requested by the client.
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Although the firm does not have custody, Hapanowicz has established procedures to ensure all client
funds and securities are held at a qualified custodian in a separate account for each client under that
client’s name. Clients or an independent representative of the client will direct, in writing, the
establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the
manner in which the funds or securities are maintained. Finally, account statements are delivered directly
from the qualified custodian (e.g. National Financial Services or SEI Trust) to each client, or the client’s
independent representative, at least quarterly. Clients should carefully review those statements and are
urged to compare the statements against any information received directly from Hapanowicz. When
clients have questions about their account statements, they should contact Hapanowicz or the qualified
custodian preparing the statement.
Item 16 – Investment Discretion
Upon receiving written authorization from the client, Hapanowicz may implement trades on a discretionary
basis (as detailed in our agreement for services). When discretionary authority is granted, Hapanowicz
will have the authority to determine the type of securities and the amount of securities that can be bought
or sold for the client’s portfolio without obtaining the client’s consent for each transaction.
If you decide to grant trading authorization on a non-discretionary basis, we will be required to contact
you prior to implementing changes in your account. Therefore, you will be contacted and required to
accept or reject our investment recommendations including:
• The security being recommended
• The number of shares or units
• Whether to buy or sell
Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing
of buying or selling an investment and the price at which the investment is bought or sold. If your
accounts are managed on a non-discretionary basis, you need to know that if you are not able to be
reached or are slow to respond to our request, it can have an adverse impact on the timing of trade
implementations and we may not achieve the optimal trading price.
All clients have the ability to place reasonable restrictions on the types of investments that may be
purchased in an account. Clients may also place reasonable limitations on the discretionary power
granted to our firm so long as the limitations are specifically set forth or included as an attachment to the
client agreement.
Item 17 – Voting Client Securities
Clients are given the option to vote proxies themselves or have Hapanowicz vote proxies on their behalf.
If granted this authority, we will act in the best interest of shareholders when voting proxies.
With respect to assets managed by a third-party money manager, we will not vote the proxies associated
with these assets. Please refer to each third-party money manager’s disclosure brochure to determine
whether the third-party money manager will vote proxies on your behalf. You may request a complete
copy of third-party money manager’s proxy voting policies and procedures as well as information on how
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your proxies were voted by contacting the third-party money manager or by contacting Hapanowicz at the
address or phone number indicated on Page 1 of this disclosure document.
Item 18 – Financial Information
This item is not applicable to this brochure. Hapanowicz & Associates Financial Services, Inc. is not
subject to a financial condition that is reasonably likely to impair its ability to meet contractual
commitments to clients. Finally, Hapanowicz & Associates Financial Services, Inc. has not been the
subject of a bankruptcy petition at any time.
Business Continuity Plan
Hapanowicz has a Business Continuity and Disaster Recovery Plan in order to provide guidance
regarding the steps and actions that should be taken in the event of an unanticipated interruption of
normal business operations. Hapanowicz has written this Plan anticipating two kinds of Significant
Business Disruptions (SBDs): internal and external. Internal SBDs affect our ability to communicate and
do business, for example, a fire in our building. External SBDs prevent the operation of the securities
markets or a number of firms. Examples of an external SBD include terrorist attacks, a city flood, or a
wide-scale, regional disruption. Our response to an external SBD relies more heavily on other
organizations and systems, especially on the capabilities of any clearing firms or outside investment
advisor firms with which we have established a relationship.
This plan will help us to safeguard employees’ lives and firm property, to allow us a method of making
financial and operational assessments, to recover and resume business operations in a rapid and efficient
manner, to protect our firm’s books and records, to continue to allow our clients to transact business at all
times and to provide our clients with access to their funds and securities in the event we determine that
we cannot continue to do business.
The plan includes the following:
• Business Description
• Office Locations
• Customers’ Access to Funds and Securities
• Data Back-Up and Recovery (Hard Copy and Electronic)
• Financial and Operational Assessments
• Mission Critical Systems
• Alternate Communications Between the Firm and Customers, Employees, and Regulators
• Critical Business Constituents, Banks, and Counterparties
• Regulatory Reporting
• Details on the Firms’ Succession Plan
Our Business Continuity and Disaster Recovery plan is reviewed and updated on a regular basis to
ensure that the policies in place are sufficient and operational.
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CUSTOMER PRIVACY NOTICE
Hapanowicz is committed to safeguarding the confidential information of its clients. We hold all personal
information provided by our clients in the strictest confidence. We have relationships with other non-
affiliated investment advisors, insurance companies, trust companies, custodians and other financial
institution entities. Except as required or permitted by law, we do not share confidential information about
clients with non-affiliated third parties. In the unlikely event there were to be a change in this fundamental
policy that would permit additional disclosures of client confidential information, the applicant will provide
written notice to its clients and clients will be given an opportunity to direct the applicant as to whether
such disclosure is permissible.
AN IMPORTANT NOTICE CONCERNING CUSTOMERS’ PRIVACY
CUSTOMER INFORMATION WE COLLECT. We collect and develop personal information about clients
and some of that information is nonpublic personal information (Customer Information). The essential
purpose for collecting Customer Information is to provide and service the financial products and services
clients obtain from our firm. The categories of Customer Information we collect depend upon the scope of
the engagement with the client and are generally described below.
As an investment advisor, we collect and develop Customer Information about clients in order to provide
investment advisory services. Customer Information we collect includes:
Information received from clients on financial inventories through consultations. This
Customer Information may include personal and household information such as income,
spending habits, investment objectives, financial goals, statements of account and other records
concerning clients’ financial condition and assets, together with information concerning employee
benefits and retirement plan interests, wills, trusts, mortgages and tax returns.
Information developed as part of financial plans, analyses or investment advisory services.
Information concerning investment advisory account transactions, such as wrap account
transactions.
Information about a client’s financial products and services transactions with the applicant.
DATA SECURITY. Hapanowicz restricts access to Customer Information to those associated persons
and employees who need the information to perform their job responsibilities. We maintain agreements,
as well as physical, electronic and procedural securities measures that comply with federal regulations to
safeguard Customer Information about clients.
USE AND DISCLOSURE OF CUSTOMER INFORMATION TO PROVIDE CUSTOMER SERVICE FOR
ACCOUNTS. To administer, manage and service customer accounts, process transactions and provide
related services for client accounts, it is necessary for us to provide access to Customer Information
within the firm and to non-affiliated companies such as investment advisors, other broker/dealers, trust
companies, custodians and insurance companies. Hapanowicz may also provide Customer Information
outside of the firm as permitted by law, such as to government entities, consumer reporting agencies or
other third parties in response to subpoenas.
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FORMER CLIENTS. When clients close an account with Hapanowicz, it will continue to operate in
accordance with the principles stated in the Notice.
REQUIREMENTS OF FEDERAL LAW. In November of 1999, Congress enacted the Gramm-Leach-
Bliley Act (GLBA). The GLBA requires certain financial institutions, including broker-dealers and
investment advisors, to protect the privacy of Customer Information. To the extent a financial institution
discloses Customer Information to non-affiliated third parties, other than as permitted or required by law,
customers must be given the opportunity and means to opt out (or prevent) such disclosure. Please note
that that the applicant does not disclose Customer Information to non-affiliated third parties, except as
permitted or required by law (e. g., disclosures to service a client’s account or to respond to subpoenas).
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