Harbour Financial Resources, Ltd.

FORM ADV PART 2A BROCHURE of Harbour Financial Resources, Ltd. 9933 Lawler Ave., Suite 500 Skokie, Illinois 60077 Telephone: 847-675-6836 Email: rleon@hfrltd.com This brochure provides information about the qualifications and business practices of Harbour Financial Resources, Ltd. If you have any questions about the contents of this brochure, please contact Robert A. Leon at (847) 675-6836 and at rleon@hfrltd.com The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Harbour Financial Resources, Ltd. is also available on the SEC’s website at www.adviserinfo.sec.gov. The Adviser’s IARD number is 110261. Harbour Financial Resources, Ltd. is a Registered Investment Adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. March 30, 2026  Material Changes Form ADV Part 2A, Item 2 This Item will be used to provide our clients with a summary of new and/or updated information. We will inform you of the revision(s) based on the nature of the updated information. As required, we will provide a summary of any material changes to this and subsequent annual Brochure filings within 120 days of the close of our business’ fiscal year. Furthermore, we will provide you with other interim disclosures about material changes as necessary. Since the last annual update of our Brochure on February 25, 2025, we note the following material changes: • We added additional detail around risk in Item 8. • We added information about the benefits that HFR receives from Schwab in Item 12. • We updated the frequency of reports in Item 13. ii  Table of Contents Adv Part 2A, Item 3 Material Changes ............................................................................................... ii Advisory Business .............................................................................................. 1 Fees and Compensation ...................................................................................... 4 Performance-Based Fees and Side-By-Side Management ................................. 8 Types of Clients .................................................................................................. 9 Methods of Analysis, Investment Strategies and Risk of Loss .......................... 10 Disciplinary Information .................................................................................... 13 Other Financial Industry Activities and Affiliations ......................................... 14 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............................................................................................................. 15 Brokerage Practices .......................................................................................... 16 Review of Accounts ........................................................................................... 19 Client Referrals and Other Compensation ....................................................... 20 Custody ............................................................................................................. 21 Investment Discretion ...................................................................................... 22 Voting Client Securities ................................................................................... 23 Financial Information ...................................................................................... 24 iii  Advisory Business Form ADV Part 2A, Item 4 Harbour Financial Resources, Ltd. (“HFR”) is an SEC registered investment adviser which provides investment supervisory services and financial planning consultations for individuals and business entities. Its principal place of business is in Skokie, Illinois. HFR has been in business since 1994 and is owned by Robert A. Leon, its President. Types of Services A. Financial Planning HFR provides financial planning services for individuals and business entities. Financial Planning services for individuals include, but are not limited to the following: financial statement review, portfolio analysis, tax planning, and other applicable financial aspects of one’s life. If appropriate, a comprehensive plan will be prepared, which will assess the client’s current overall situation, address the above concerns, and provide recommendations for changes which can assist in the achievement of the client’s goals and objectives. Business financial planning includes selection of the proper form of doing business, employee benefits, business continuation, business documentation, buy/sell agreements, non-qualified compensation planning, pension planning, and other business concerns which apply. Upon presentation of the written plan, if the client is not satisfied with the services provided by HFR, and HFR is not able to correct the plan to the client’s satisfaction, HFR will refund all fees paid. In that instance, the client agrees to return the plan to HFR. Investment Supervisory Services HFR also offers investment planning and consultation on a non-discretionary basis and for a fee based upon assets under management. This program is designed to permit HFR to purchase and sell primarily no-load mutual funds pursuant to client’s investment policy statement and objectives. Some mutual funds that HFR selects have different share classes. These share classes have varying account minimums, fees, and expense structures. HFR uses a variety of tools to determine a client’s suitability for certain investments including a risk questionnaire, client profile, and meetings with the client. After reviewing the above, HFR will make recommendations of securities based upon that information. A client may notify HFR of any restrictions as to the purchases or sales of securities in their 1  account and HFR will note and honor those restrictions. In order to establish that an investment is suitable for a client, HFR employs the use of Client Profiles and Risk Profiles. HFR advises on securities including equities, debt instruments, commercial paper, government bonds, corporate bonds, mutual funds, secured notes, and exchange-traded funds. Most client assets are held at Charles W. Schwab (“Schwab” or the “Custodian”) and those client transactions are cleared through Schwab Institutional pursuant to the Adviser’s clearing agreement with Schwab. The custody of client funds and securities are maintained by Schwab, not HFR. Pershing/Lockwood Financial Services also serves as custodian of some clients’ assets. During any month that there is activity the Client will receive a monthly account statement from the account custodian showing account activity as well as positions held in the account at month end. Additionally, the client receives a confirmation of each transaction that occurs within the account. This program can be terminated by either party upon written notice, which shall be effective when received by the other party or upon the passing of thirty (30) business days from the date of termination notice, whichever occurs sooner. HFR is a fiduciary under section 4975 of the Internal Revenue Code of 1986, as amended (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, HFR. is subject to specific duties and obligations under ERISA and the IRC, as applicable, that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice, the fiduciary must either avoid certain conflicts of interest or rely upon an applicable prohibited transaction exemption (a “PTE”). As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess. Recommendation of Third-Party Advisors If during the review of a clients’ portfolio, it is recommended that the client utilize the services of individually managed account(s), the client will be advised to utilize the services of another advisor or broker-dealer such as but not limited to, Lockwood Financial Services/Pershing. 2  Assets Under Management As of December 31, 2025, HFR had $189 ,816,445 under management on a non- discretionary basis only. 3  Fees and Compensation Form ADV Part 2A, Item 5 Financial Planning HFR provides financial planning services on an hourly basis with the rates ranging from $40 per hour to $500 per hour (hereinafter referred to as the “Fee”), depending upon the qualifications and experience of the staff person performing the work and the circumstances of the planning situation. Furthermore, a client may choose to utilize the financial planning format on a modular basis, whereby the client chooses which areas of their financial realm they wish to have reviewed and analyzed. The first module fee is $1000, and each module thereafter is $750 each. Additional modular fees range from $750 on up depending on work required. A minimum retainer fee of at least $500 is payable upon signing of the engagement agreement. The balance will be payable upon presentation of the written plan. (Plans are generally completed within four months). Generally, HFR bills on a monthly basis. Billing to business clients can be either on a retainer basis or monthly billing based on time incurred. Investment Supervisory Services 1. Adviser’s Fee: HFR charges a fee based upon a percentage of assets under management for clients who utilize its investment supervisory services. The Adviser’s fee schedule is typically as follows: 4  Portfolio Value Annual Fee Annual Fee if Option* Investing is Desired Annual Fee on Outside Assets Personally Held 0 to $100,000 1.25% of account balance Not Available .25% on asset balance as provided by client $100,001 to $1,000,000 .25% on asset balance as provided by client 1.0% on first $100,000 .75% from $100,001 to $1,000,000 1.25% on first $100,000 1.0% from $100,001 to $1,000,000 $1,000,000 to $5,000,000 .25% on asset balance as provided by client 1.0% on first $100,000 .75% from $100,001 to $1,000,000 .35% from $1,000,001 to $5,000,000 1.25% on first $100,000 1.0% from $100,001 to $1,000,000 .50% from $1,000,001 to $5,000,000 $5,000,000+ .25% on asset balance as provided by client 1.0% on first $100,000 .75% from $100,001 to $1,000,000 .35% from $1,000,001 to $5,000,000 .25% from $5,000,001 and up 1.25% on first $100,000 1.0% from $100,001 to $1,000,000 .50% from $1,000,001 to $5,000,000 .40% from $5,000,001 and up *Option Investing refers to the utilization of options (Puts, Calls, etc.) as part of your investing program. There is an additional fee, due to the increased time and analysis required. The account fee is paid quarterly, in arrears, based upon the value of the assets in the clients’ account as of the last day of the previous quarter. The first account fee will be paid quarterly in arrears, prorated based on the date HFR begins providing investment supervisory services. Subsequent account fees are due and will be assessed based on the value of the account assets under supervision as adjusted for quarterly withdrawals and deposits (cash flow) as of the close of business on the last business day of the preceding quarter as valued by the custodian. HFR charges a minimum annual fee of $3000.00 per account/household. Fees actually paid will be credited against the $3000.00 minimum and the client account will be debited from the client’s account or the client will be invoiced for the balance. The annual advisory fee is on the entire account balance, including cash and accrued interest. Fees shall be paid directly to HFR by the custodian subject to pre-authorization to the custodian by Client. If during a quarter the client chooses to utilize HFR’s additional options investing service (puts, call, etc.), then the client will automatically be subject to that schedule as shown above to be applied to the quarter in which the change occurs and vice versa, if that schedule was not originally selected. If selected, the annual fee on outside assets such as 401k plans or assets not under direct supervision by HFR will be assessed a fee as shown, to be calculated by a client provided statement of that asset. The fee will be 5  calculated on that account balance and ratable (spread over the upcoming quarters starting at the beginning of the next year) added to the quarterly investment advisory fee as calculated (beginning with the next year) in either the Annual Fee column or the Annual Fee if Option Investing is Desired column. If the client chooses to decline this fee, then the client will, under certain circumstances, incur additional financial planning update fees. Additional deposits or withdrawals of funds and/or securities on existing accounts are subject to the same billing procedure. If assets are deposited or withdrawn by a client after the inception of a quarter, the account fee payable with respect to such assets is pro-rated based on the number of days remaining in the quarter. Account fees are deducted directly from the client’s account pursuant to the Investment Advisory Agreement. Clients may also request that these quarterly fees be billed to them directly or to a specific account upon agreement by HFR and the client, on a case-by-case basis. In addition, HFR is authorized to sell certain positions in Client’s accounts in order to pay HFR’s quarterly fees or as required by Client’s withdrawals. We will access other accounts to avoid short term redemption fees and any other costs as we see fit in order to satisfy quarterly management fees. The above stated fee arrangement are negotiated on a case-by-case basis. 2. Additional Fees and Expenses In addition to the account fee stated above, clients will pay fees and expenses associated with the investment of their assets including transaction costs for execution of trades in their account. These include custodial fees, commissions, and loads on mutual fund shares as well as other expenses and charges imposed by broker-dealers and custodians who service client accounts (including but not limited to any custodian fees and account maintenance fees). HFR’s brokerage practices are detailed in the section entitled Brokerage Practices. Clients are additionally responsible for the fees and expenses of externally managed investments, such as third-party managers and/or investment advisers, and of mutual funds and exchange traded funds. In the event that the client chooses to purchase a mutual fund that charges a load, the standard sales charges listed in the fund’s prospectus will apply. There are no extra transaction fees associated with a fund that imposes a load. The quarterly fee as discussed above will also be assessed against these funds. HFR does not receive any commissions on these transactions. 6  All mutual funds pay management fees to their investment advisers and certain funds have other types of fees or charges, including 12b-1 fees, administrative fees, or shareholder servicing fees, which will be deducted from the net asset value of the mutual funds held in a client’s portfolio. These types of fees are routinely borne by all mutual fund shareholders as an indirect expense to their account and are in addition to the management fees charged by HFR. Some mutual funds that HFR selects have different share classes. These share classes have varying account minimums, fees, and expense structures. HFR does not receive any of these fees. 7  Performance-Based Fees and Side-By-Side Management Form ADV Part 2A, Item 6 HFR does not charge performance fees on client accounts. 8  Types of Clients Form ADV Part 2A, Item 7 HFR generally provides investment advice to individuals, high net worth individuals, pension and profit-sharing plans, and trusts or estates. 9  Methods of Analysis, Investment Strategies and Risk of Loss Form ADV Part 2A, Item 8 HFR uses fundamental and technical methods of analysis to formulate investment advice based on various sources of information, including financial newspapers and magazines, research materials not prepared by HFR, and corporate ratings services, as well as the various filings companies make with the Securities and Exchange Commission, including annual reports, prospectuses and other filings. HFR does not use any specific models. Investing style and recommendations are based on risk tolerance and the client’s personal financial goals, objectives and needs. HFR renders investment advice concerning equities, debt instruments, commercial paper, government bonds, corporate bonds, mutual funds, secured notes, secured notes and Exchange Traded Funds. Risk of Loss: All investments are subject to the risk of loss which clients should be prepared to bear. All investments present the risk of loss of principal – the risk that the value of the securities (e.g., stocks, mutual funds, and ETFs), when sold or otherwise disposed of, may be less than the price paid for the securities. Even when the value of the securities when sold is greater than the value when purchased, there is the risk that the appreciation will be less than inflation. In other words, the purchasing power of the proceeds may be less than the purchasing power of the original investment. Investments such as those primarily used by HFR for client portfolios (including, but not limited to, stocks, mutual funds, and ETFs) are not deposits in a bank and are not insured or guaranteed by the Federal Deposit Insurance Corporation or any other governmental agency. Risks of Equities: Investing in equity securities generally involves becoming an owner in the issuer company and participating fully in its economic risks. The value of equity securities generally varies with the performance of the issuer and movements in the equity markets. As a result, clients may suffer losses if they invest in equity instruments of issuers whose performance diverges from the Firm’s expectations or if equity markets generally move in a single direction. Markets periodically experience recessions, panics, crashes and other periods of volatility that can cause substantial losses in the equity securities in clients’ investment portfolios. Risks of Mutual Funds and ETFs: Mutual funds are professionally managed, collective investment companies that pool money from many investors and invest in various asset classes, including equities, fixed-income instruments (e.g., bonds), cash, and other assets. ETFs are investment funds traded on stock exchanges, much like stocks and other 10  equities. An ETF may hold stocks, bonds, and/or other assets. Many ETFs track an index, such as the S&P 500. An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. More information regarding the specific risks associated with investment in a particular mutual fund is available in that mutual fund’s prospectus. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed based ETFs and potentially more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 50,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. More information regarding the specific risks associated with investment in a particular mutual fund or ETF is available in its prospectus. • • • • • In addition to the risks discussed above, clients should consider the following risks: Financial Market Volatility. Financial markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments. Different sectors of the market can react differently to these developments. Foreign Exposure. Mutual funds and ETFs which are invested in foreign markets can be more volatile than the U.S. market due to increased risks of adverse issuer, political, regulatory, market, or economic developments and can perform differently from the U.S. market. Concentration Risk. A fund may be exposed to a particular sector, region, product, or industry that experiences volatility. Manager Risk. A fund manager’s investment process, techniques, and analysis may not produce the desired results. Leverage. A fund or company in which a fund holds shares may utilize borrowed capital to augment the potential for return thereby concomitantly increasing exposure to debt. 11  • • Layering of Expenses and Fees. Mutual funds and ETFs are subject to fees and expenses that are paid by an investor which are in addition to our advisory fees. Liquidity. Although typically associated with micro-cap and small-cap stocks or securities, liquidity risks can arise during times of market financial crisis. The risk arises when there is a lack of marketability for a fund’s underlying security that cannot be bought or sold quickly enough to prevent or mitigate a loss. Option Risk: Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option writing also involves risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Cybersecurity Risk: The computer systems, networks, and devices used by HFR. and service providers to us and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks, or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes, or website access or functionality. Cybersecurity breaches may cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issuers of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers, and other financial institutions; and other parties. In addition, substantial costs may be incurred by these entities in order to prevent any cybersecurity breaches in the future. 12  Disciplinary Information Form ADV Part 2A, Item 9 Neither HFR nor its owner, Robert Leon, has any disciplinary information to report. 13  Other Financial Industry Activities and Affiliations Form ADV Part 2A, Item 10 HFR is licensed as an insurance agency with the State of Illinois. Robert A. Leon, President of HFR, and Michael G. Vieceli, an advisory representative of HFR, as insurance agent, receive usual and ordinary insurance/annuity commissions for the placement of insurance/annuities in client accounts. HFR is licensed to sell life, health, and disability insurance as well as annuities. This practice creates a conflict of interest between HFR and the client in that it gives an incentive for HFR agents to recommend products based upon the compensation received. However, the needs of the client will always supersede HFR’s compensation considerations. HFR addresses this conflict by notifying clients, including in this Brochure, that they are not obligated to purchase any insurance, financial products, or any other investments through HFR. Moreover, HFR will in some cases recommend other brokers or insurance agents for these services. Commissions payable to Robert A. Leon and/or Michael G. Vieceli are similar to commissions that are paid in the industry, so clients do not pay more by utilizing HFR’s services for these other products. In addition, due to HFR’s relationships with providers of investment and insurance products, HFR can and has utilized discounts on the purchase of software used in HFR’s day-to-day operations. Moreover, HFR obtains investment advisory services and managed money products from Lockwood Financial Services, Inc., a registered Broker-Dealer and investment advisor, through its Managed Account Link and Mutual Fund Link programs. Clients contract with Lockwood Financial Services, Inc. for these services and products. HFR will collect certain financial information regarding clients and make that information available to Lockwood. Client is referred to Lockwood ADV, Part 2, Schedule H (wrap fee brochure) for a complete discussion and disclosure regarding its programs. 14  Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Form ADV Part 2A, Item 11 HFR has adopted a Code of Ethics pursuant to Section 204A-1 of the Advisers Act. That Code governs HFR’s conduct concerning such matters as insider trading, personal securities trading, outside business activities, and gifts. Specifically, the Code prohibits the use of material non-public information in both employee accounts and for client accounts. In addition, the Code requires that employees follow the structure set forth below regarding trading in securities that clients are also purchasing and selling. In order to monitor employees personal securities trading, the Code requires an initial holdings report for new employees, an annual holdings report for current employees and quarterly reporting by employees of their personal securities by furnishing, electronically or by paper, duplicate copies of their brokerage statements. The Code also sets forth limits for the giving or receipt of gifts by HFR and its employees. A client may receive a copy of HFR’s Code of Ethics upon request. HFR or its employees will, from time to time buy or sell securities that HFR buys or sells for its clients. The timing of these purchases will depend upon the investment circumstances of the parties involved. However, if HFR or any of its employees purchases or sells securities simultaneously with one of HFR’s clients, then the client will receive preference in execution and price. 15  Brokerage Practices Form ADV Part 2A, Item 12 Financial Planning For financial planning clients, HFR will in some cases recommend certain brokers to clients for the purpose of implementing their financial plan. Generally, this includes the purchase and sale of securities and certain insurance products. Based upon information provided by these referral sources, clients of HFR will pay fees and/or commissions that are substantially similar to other brokers or advisors for similar products and services. The facts and circumstances related to the client (complexity of plan, location of client, dollars to be invested, etc.) are considered in determining to which broker or brokers HFR will refer the client. Brokerage for Investment Management For the brokerage to be implemented for its investment supervisory services, HFR considers certain factors before suggesting a particular brokerage firm to clients, including: the products offered, the level of service, execution, potential price/commission reductions and the ability to meet client needs. In assessing the reasonableness of their commissions, HFR compares various brokerage firm rates and advises clients of the best overall firm. HFR remains flexible in the use of other brokerage firms upon client request or where otherwise appropriate. Generally, however, HFR will effect securities transactions through Schwab for its investment management clients, since Schwab acts as custodian for most client accounts. HFR does not receive research or any other investment related products from Schwab in return for placing its clients’ brokerage there. Directed Brokerage HFR does not allow for clients to direct brokerage to other broker-dealers HFR remains flexible in the use of Schwab as custodian for client accounts. Soft Dollars HFR does not receive research or any other investment related products from Schwab in return for placing its clients’ brokerage there. 16  Trade Aggregation and Trade Allocations Due to the fact that HFR acts on a non-discretionary basis only with clients, it does not block client trades, nor does it allocate from any type of group fill. Trade Errors HFR corrects all trade errors through a Trade Error Account. HFR will pay for any loss for an incorrect trade in a client account. If there is any gain due to a trade error, Schwab will retain the gain. Additional Benefits from Agreements with Service Providers Schwab provides HFR with certain benefits and services which include access to the Custodian’s institutional trading and operations services, including research, and other products and services. These products and services may benefit HFR directly without necessarily benefiting individual client accounts, either directly or indirectly. Other products and services assist HFR in managing and administering clients’ accounts. These include the provision of software and other technologies to access client account data (such as trade confirmations and account statements); facilitation of trade execution; provision of pricing information and other market data; facilitation of payment of HFR’s fees from its clients’ accounts; and assistance with back-office support, recordkeeping, and client reporting. Many of these products and services may be used to service all HFR’s accounts, including those accounts not maintained at the Custodian. These products and services may not benefit all of HFR’s client accounts equally and may not benefit certain client accounts at all. The Custodian also provides HFR with other services intended to help HFR manage and further develop its business enterprise. These services can include consulting, publications, and presentations on practice management, information technology, business succession, regulatory compliance, and marketing. Schwab can on occasion also provide other benefits such as educational conferences and events. These services may be provided by the Custodian; in other cases, they may arrange for third-party vendors to provide the services to HFR. Additionally, the Custodian may discount or waive fees they 17  would otherwise charge HFR for some of these services or pay all or a part of the fees of a third party providing these services to HFR. HFR does not make a commitment to invest any specific amount or percentage of client assets in any specific mutual funds, securities, or other products as a result of the above arrangement. However, HFR’s receipt of these products and services from the Custodian creates a conflict of interest as these benefits may influence HFR’s decision to recommend them over other service providers that do not furnish similar support, services, or software to HFR. HFR believes that the foregoing products and services are customary and typical of products and services custodians provide to investment advisers similar to HFR, and further believes that the retention of Custodian is in the best interest of HFR’s clients. 18  Review of Accounts Form ADV Part 2A, Item 13 Robert A. Leon, CPA and CFP and Michael Vieceli, CFP, review HFR accounts. Client accounts are reviewed at least annually but will be done more frequently if a client request a review, or economic circumstances trigger such a review. These economic circumstances include an increase in the volume of requests by the client for transactions or liquidations, or a change in the overall performance of the account. External factors that trigger more frequent reviews could include economic volatility of the markets, war, or natural disasters. Per the client’s request, HFR will review only a portion of their plan or investments. These are done on a case by case basis. The number of accounts is shared between Robert Leon and Michael Vieceli. Custodians of client accounts send account statements, at least quarterly, to HFR clients whether they are direct clients or clients whose accounts are managed by a third-party money manager. These statements include a complete listing of all account activity, holdings and current values. In addition, HFR will periodically send written reports to certain clients who have assets under management. 19  Client Referrals and Other Compensation Form ADV Part 2A, Item 14 HFR does not any pay referral fees. If HFR were to pay referral fees to certain advisors for referring clients to HFR, such arrangements would be in compliance with Rule 206(4)- 1 of the Investment Advisers Act of 1940. 20  Custody Form ADV Part 2A, Item 15 While HFR does not have actual physical custody of client funds or securities, the SEC deems HFR to have legal custody over client assets under certain circumstances, such as when clients authorize HFR through standing instructions (“SLOAs”) to instruct qualified custodians to transfer assets to third parties and client accounts are deducted directly from the client’s account pursuant to the Investment Advisory Agreement. Assets are custodied at an unaffiliated, qualified custodian who sends account statements, at least quarterly to clients. Clients should carefully review these statements. Periodically or upon request, HFR will send portfolio statements to clients. HFR strongly urges clients to compare these performance statements to their custodian statements for accuracy and completeness. 21  Investment Discretion Form ADV Part 2A, Item 16 HFR does not accept discretionary authority to manage securities accounts on behalf of any clients. 22  Voting Client Securities Form ADV Part 2A, Item 17 As a matter of firm policy, HFR does not vote client securities on behalf of clients. Clients are responsible for instructing each custodian of the client’s assets to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. Should a client have questions regarding a particular proxy solicitation, they can contact HFR at 847-675-6836. 23  Financial Information Form ADV Part 2A, Item 18 HFR has not been the subject of a bankruptcy petition at any time during the past ten years, nor have any of its employees. HFR has no financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. 24