Harding Wealth, Inc.

Harding Wealth, Inc. Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Harding Wealth, Inc. If you have any questions about the contents of this brochure, please contact us at (602) 610-9545 or by email at: adam@hardingwealth.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 Harding Wealth, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. Harding Wealth, Inc.’s CRD number is: 282686. 222 S. Mill Avenue #800 Tempe, AZ 85281 (602) 610-9545 www.hardingwealth.com adam@hardingwealth.com Registration does not imply a certain level of skill or training. Version Date: 03/13/2026 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Harding Wealth, Inc. on 2/28/2025 are described below. Material changes relate to Harding Wealth, Inc.’s policies, practices or conflicts of interests. • Harding Wealth, Inc. has updated its Fees and Compensation (Item 5) i  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ............................................................................................................................................................................... i Item 3: Table of Contents .............................................................................................................................................................................. ii Item 4: Advisory Business ............................................................................................................................................................................ 2 A. Description of the Advisory Firm ...................................................................................................................................................... 2 B. Types of Advisory Services ................................................................................................................................................................. 2 C. Client Tailored Services and Client Imposed Restrictions .............................................................................................................. 3 D. Wrap Fee Programs ............................................................................................................................................................................. 4 E. Assets Under Management ................................................................................................................................................................. 4 Item 5: Fees and Compensation ................................................................................................................................................................... 4 A. Fee Schedule ......................................................................................................................................................................................... 4 B. Payment of Fees .................................................................................................................................................................................... 5 C. Client Responsibility For Third Party Fees ....................................................................................................................................... 5 D. Prepayment of Fees.............................................................................................................................................................................. 6 E. Outside Compensation For the Sale of Securities to Clients ........................................................................................................... 6 Item 6: Performance-Based Fees and Side-By-Side Management ........................................................................................................... 6 Item 7: Types of Clients ................................................................................................................................................................................. 6 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss................................................................................................... 7 A. Methods of Analysis and Investment Strategies ...................................................................................................................... 7 B. Material Risks Involved ............................................................................................................................................................... 7 C. Risks of Specific Securities Utilized ........................................................................................................................................... 9 Item 9: Disciplinary Information ............................................................................................................................................................... 11 A. Criminal or Civil Actions .......................................................................................................................................................... 11 B. Administrative Proceedings ..................................................................................................................................................... 11 C. Self-regulatory Organization (SRO) Proceedings .................................................................................................................. 11 Item 10: Other Financial Industry Activities and Affiliations ................................................................................................................ 11 A. Registration as a Broker/Dealer or Broker/Dealer Representative .................................................................................... 11 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor..... 11 C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ............................... 11 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ...................... 12 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................................................... 12 A. Code of Ethics ............................................................................................................................................................................. 12 B. Recommendations Involving Material Financial Interests ................................................................................................... 12 C. Investing Personal Money in the Same Securities as Clients ................................................................................................ 13 ii  D. Trading Securities At/Around the Same Time as Clients’ Securities ................................................................................. 13 Item 12: Brokerage Practices ....................................................................................................................................................................... 13 A. Factors Used to Select Custodians and/or Broker/Dealers ................................................................................................. 13 1. Research and Other Soft Dollar Benefits ............................................................................................................................. 13 2. Brokerage for Client Referrals .............................................................................................................................................. 15 3. Clients Directing Which Broker/Dealer/Custodian to Use ............................................................................................. 15 B. Aggregating (Block) Trading for Multiple Client Accounts ................................................................................................. 15 Item 13: Review of Accounts ...................................................................................................................................................................... 15 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews................................................................... 15 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts................................................................................ 15 C. Content and Frequency of Regular Reports Provided to Clients ......................................................................................... 16 Item 14: Client Referrals and Other Compensation ................................................................................................................................ 16 Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other A. Prizes) 16 B. Compensation to Non – Advisory Personnel for Client Referrals ....................................................................................... 17 Item 15: Custody .......................................................................................................................................................................................... 17 Item 16: Investment Discretion .................................................................................................................................................................. 18 Item 17: Voting Client Securities (Proxy Voting) ..................................................................................................................................... 18 Item 18: Financial Information ................................................................................................................................................................... 19 A. Balance Sheet .............................................................................................................................................................................. 19 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ................... 19 C. Bankruptcy Petitions in Previous Ten Years .......................................................................................................................... 19 iii  Item 4: Advisory Business A. Description of the Advisory Firm Harding Wealth, Inc. (hereinafter “HW”) is a corporation organized in the State of Arizona. The firm was originally formed in January 2016, and the principal owner is Adam Clark Harding. B. Types of Advisory Services Portfolio Management Services HW offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. HW creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring HW evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. HW will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. HW seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of HW’s economic, investment or other financial interests. To meet its fiduciary obligations, HW attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, HW’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is HW’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. 2  Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. In offering financial planning, a conflict exists between the interests of the investment adviser and the interests of the client. The client is under no obligation to act upon the investment adviser's recommendation, and, if the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through the investment adviser. This statement is required by California Code of Regulations, 10 CCR Section 260.235.2. Services Limited to Specific Types of Investments in the gold and precious metal sectors), treasury HW generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements, although HW primarily recommends diversified fee-conscious portfolios with a focus on liquidity, transparency, and academic research. to a majority of its clients. HW may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions HW will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by HW on behalf of the client. HW may use “model portfolios” together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Investment advisory services will be the tailored as a result of four key items: Risk Tolerance (How well an investor can digest volatility), Risk Capacity (How much risk can be taken given the investor's personal financial situation), Investment Objectives (What rate of return is needed to meet the investment objectives outlined in the investors financial plan), and the Investment Landscape (What are the predominate risks and opportunities in the investable universe). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent HW from properly servicing the client account, or if the restrictions would require HW to deviate from its standard suite of services, HW reserves the right to end the relationship. 3  D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. HW does not participate in any wrap fee programs. E. Assets Under Management HW has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $212,623,954.00 $0.00 December 2025 Item 5: Fees and Compensation A. Fee Schedule Asset-Based Fees for Portfolio Management Total Assets Under Management Annual Fee $0 to $2,500,000 1.00% Over $2,500,000 0.50% Lower fees for comparable services may be available from other sources. These fees are generally negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of HW's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. HW, in its discretion, may negotiate fees based upon individual account criteria such as anticipated future assets, client’s unique circumstances, and additional services performed. Our fees may be higher or lower than fees charged by other financial professionals offering similar services. HW reserves the right to modify its fee schedule in the future by providing 30 days advance notice of any modification. HW, in its discretion, may also reserve the right to reduce client fees without 30 days’ notice. 4  *a $100 annual fee may be assessed on accounts with values below $50,000. This fee is used to partially defer technology costs. For account values of less than $10,000, this may equate to be more than the maximum stated 1% as stated in this Form ADV and the Agreement HW uses the value of the account as of the last business day of the prior billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Financial Planning Fees Clients may terminate the agreement without penalty for a full refund of HW's fees within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. HW also provides education to 401(k) plan participants. It is an annual fee (fixed to $4,000/year) paid quarterly, that does not pertain to plan assets Specific advice and management for the account(s) are not provided. The negotiated fixed rate for creating client financial plans is between $100 and $5,000. Fees are charged in arrears upon completion. B. Payment of Fees Payment of Asset-Based Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis. Fees are paid in advance. The custodian is provided with the applicable fee schedule upon commencement of the client’s account opening, will calculate the advisory fees, and will issue to the client a statement of advisory fees each billing period. HW itself does not provide separate invoices. Payment of Financial Planning Fees Financial planning fees are paid via check and cash, in arrears upon completion. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by HW. Please see Item 12 of this brochure regarding broker-dealer/custodian. 5  D. Prepayment of Fees HW collects certain fees in advance and certain fees in arrears, as indicated above. Refunds for fees paid in advance will be returned within fourteen days to the client via check, or return deposit back into the client’s account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) E. Outside Compensation For the Sale of Securities to Clients Neither HW nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management HW does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients HW generally provides advisory services to the following types of clients: ❖ Individuals ❖ High-Net-Worth Individuals Minimum Account Size There is no account minimum for any of HW’s services. 6  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis HW’s methods of analysis include charting analysis, fundamental analysis, cyclical analysis, quantitative analysis and modern portfolio theory. Charting analysis involves the use of patterns in performance charts. HW uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Investment Strategies HW uses long term trading, short term trading and options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Charting analysis strategy involves using and comparing various charts to predict long and short term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the 7  assumption that past performance will be indicative of future performance. This may not be the case. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Quantitative Model Risk: Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Modern Portfolio Theory assumes that investors are risk adverse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Investment Strategies HW's use of options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Short term trading risks include liquidity, economic stability, and inflation, in addition to the long term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that 8  an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized HW's use of options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. 9  Real Estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Private placements carry a substantial risk as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a well-diversified investment in commodities can be uncertain. 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 transactions also involve 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. 10  Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither HW nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither HW nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Adam Clark Harding is an independent licensed insurance agent, and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, 11  as commissionable products conflict with the fiduciary duties of a registered investment adviser. HW always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of HW in connection with such individual's activities outside of HW. Adam Clark Harding is Finance Chair at Arizona Literacy and Learning Center. Adam Clark Harding is Part time Instructor at UCLA Extension. All material conflicts of interest under California Code of Regulations Section 260.238(k) are disclosed regarding the investment adviser, its representatives or any of its employees, which could be reasonable expected to impair the rendering of unbiased and objective advice. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections HW does not utilize nor select third-party investment advisers. All assets are managed by HW management. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics HW has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. HW's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests HW does not recommend that clients buy or sell any security in which a related person to HW or HW has a material financial interest. 12  C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of HW may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of HW to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. HW will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of HW may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of HW to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, HW will never engage in trading that operates to the client’s disadvantage if representatives of HW buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on HW’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and HW may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in HW's research efforts. HW will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. HW will require clients to use TD Ameritrade Institutional, a division of TD Ameritrade, Inc. Member FINRA/SIPC, and Charles Schwab & Co., Inc. Advisor Services. 1. Research and Other Soft Dollar Benefits While HW has no formal soft dollars program in which soft dollars are used to pay for third party services, HW may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft 13  dollar benefits”). HW may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and HW does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. HW benefits by not having to produce or pay for the research, products or services, and HW will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that HW’s acceptance of soft dollar benefits may result in higher commissions charged to the client. HW participates in the institutional advisor program (the "Program") offered by TD Ameritrade. TD Ameritrade offers to independent investment advisor services which include custody of securities, trade execution, clearance and settlement of transactions. HW receives some benefits from TD Ameritrade through its participation in the Program. As disclosed above, HW participates in TD Ameritrade's institutional advisor program and HW may recommend TD Ameritrade to clients for custody and brokerage services. There is no direct link between HW's participation in the Program and the investment advice it gives to its clients, although HW receives economic benefits through its participation in the Program that are typically not available to TD Ameritrade retail investors. These benefits include the following products and services (provided without cost or at a discount): receipt of duplicate client statements and confirmations; research related products and tools; consulting services; access to a trading desk serving HW participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts); the ability to have HW's fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to HW by third party vendors. TD Ameritrade may also pay for business consulting and professional services received by HW's related persons. Some of the products and services made available by TD Ameritrade through the Program may benefit HW but may not benefit its client accounts. These products or services may assist HW in managing and administering client accounts, including accounts not maintained at TD Ameritrade. Other services made available by TD Ameritrade are intended to help HW manage and further develop its business enterprise. The benefits received by HW or its personnel through participation in the Program do not depend on the amount of brokerage transactions directed to TD Ameritrade. As part of its fiduciary duties to clients, HW endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by HW or its related persons in and of itself creates a conflict of interest and may indirectly influence the HW's choice of TD Ameritrade for custody and brokerage services. 14  2. Brokerage for Client Referrals HW receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use HW will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts HW does not aggregate or bunch the securities to be purchased or sold for multiple clients. This may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for HW's advisory services provided on an ongoing basis are reviewed at least annually by Adam C Harding, Principal / Chief Compliance Officer, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at HW are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Adam C Harding, Principal / Chief Compliance Officer. There is only one level of review for financial planning, and that is the total review conducted to create the financial plan. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, HW’s services will generally conclude upon delivery of the financial plan. 15  C. Content and Frequency of Regular Reports Provided to Clients Each client of HW's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. HW does not provide account statements to clients in addition to those provided by the custodian. Each financial planning client will receive the financial plan upon completion. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Charles Schwab & Co., Inc. Advisor Services provides HW with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For HW client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to HW other products and services that benefit HW but may not benefit its clients’ accounts. These benefits may include national, regional or HW specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of HW by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist HW in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of HW’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, 16  recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of HW’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to HW other services intended to help HW manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to HW by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to HW. HW is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. B. Compensation to Non – Advisory Personnel for Client Referrals HW does not compensate non-advisory personnel (solicitors) for client referrals. Item 15: Custody HW does not take custody of client accounts at any time. Custody of client’s accounts is held primarily at the client’s custodian. Clients will receive account statements from the custodian and should carefully review those statements. When advisory fees are deducted directly from client accounts at client's custodian, HW will be deemed to have limited custody of client's assets. Because client fees will be withdrawn directly from client accounts, in states that require it, HW will: (A) Possess written authorization from the client to deduct advisory fees from an account held by a qualified custodian. (B) Send the qualified custodian written notice of the amount of the fee to be deducted from the client’s account and verify that the qualified custodian sends invoices to the client. (C) Send the client a written invoice itemizing the fee upon or prior to fee deduction, including the formula used to calculate the fee, the time period covered by the fee and the amount of assets under management on which the fee was based. (D) HW will notify the California Commissioner of Business Oversight in writing that the HW intends to use the requisite safeguards per Form ADV. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. 17  Custody is also disclosed in Form ADV because HW has authority to transfer money from client account(s), which constitutes a standing letter or authorization (SLOA). Accordingly, HW will follow the safeguards specified by the SEC below rather than undergo an annual audit. 1. The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer. 4. The client has the ability to terminate or change the instruction to the client’s qualified custodian. 5. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. 6. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. 7. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16: Investment Discretion HW provides discretionary and non-discretionary investment advisory services to clients. The Investment Advisory Contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, HW generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, HW’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to HW. HW will also have discretionary authority to determine the broker dealer to be used for a purchase or sale of securities for a client's account. Item 17: Voting Client Securities (Proxy Voting) HW will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. 18  Item 18: Financial Information A. Balance Sheet HW neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither HW nor its management has any financial condition that is likely to reasonably impair HW’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years HW has not been the subject of a bankruptcy petition in the last ten years. 19