View Document Text
Harrell Investment Partners, LLC
Form ADV Part 2A – Disclosure Brochure
Effective: December 23, 2025
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Harrell Investment Partners, LLC (“HIP” or the “Advisor”). If you have any questions about the content
of this Disclosure Brochure, please contact the Advisor at (512) 759-8000 or by email at dee@harrellpartners.com.
HIP is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information
in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority.
Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure
provides information about HIP to assist you in determining whether to retain the Advisor.
Additional information about HIP and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 299166.
Harrell Investment Partners, LLC
3814 Medical Parkway;, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
https://harrellpartners.com
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of HIP.
HIP believes that communication and transparency are the foundation of its relationship with clients and will
continually strive to provide you with complete and accurate information at all times. HIP encourages all current and
prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor.
Material Changes
There have been no material changes to this Disclosure Brochure since the last annual amendment filing on
February 12, 2025.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure
Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 299166. You
may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (512) 759-8000 or by
email at dee@harrellpartners.com.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 2
https://harrellpartners.com
Item 3 – Table of Contents
1
Item 1 – Cover Page
Item 2 – Material Changes....................................................................................................................................... 2
Item 3 – Table of Contents ...................................................................................................................................... 3
Item 4 – Advisory Services ..................................................................................................................................... 4
A. Firm Information .............................................................................................................................................................. 4
B. Advisory Services Offered ............................................................................................................................................... 4
C. Client Account Management ........................................................................................................................................... 6
D. Wrap Fee Programs ........................................................................................................................................................ 6
E. Assets Under Management ............................................................................................................................................. 6
Item 5 – Fees and Compensation ........................................................................................................................... 6
A. Fees for Advisory Services.............................................................................................................................................. 7
B. Fee Billing........................................................................................................................................................................ 7
C. Other Fees and Expenses .............................................................................................................................................. 8
D. Advance Payment of Fees and Termination ................................................................................................................... 8
E. Compensation for Sales of Securities ............................................................................................................................. 9
Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................... 9
Item 7 – Types of Clients......................................................................................................................................... 9
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 9
A. Methods of Analysis ........................................................................................................................................................ 9
B. Risk of Loss ................................................................................................................................................................... 10
Item 9 – Disciplinary Information ......................................................................................................................... 11
Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 11
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 12
A. Code of Ethics ............................................................................................................................................................... 12
B. Personal Trading with Material Interest ......................................................................................................................... 12
C. Personal Trading in Same Securities as Clients ........................................................................................................... 12
D. Personal Trading at Same Time as Client .................................................................................................................... 12
Item 12 – Brokerage Practices ............................................................................................................................. 12
A. Recommendation of Custodian[s] ................................................................................................................................. 12
B. Aggregating and Allocating Trades ............................................................................................................................... 13
Item 13 – Review of Accounts .............................................................................................................................. 13
A. Frequency of Reviews ................................................................................................................................................... 13
B. Causes for Reviews ...................................................................................................................................................... 14
C. Review Reports ............................................................................................................................................................. 14
Item 14 – Client Referrals and Other Compensation ......................................................................................... 14
A. Compensation Received by HIP ................................................................................................................................... 14
B. Client Referrals from Promoters .................................................................................................................................... 14
Item 15 – Custody .................................................................................................................................................. 14
Item 16 – Investment Discretion ........................................................................................................................... 15
Item 17 – Voting Client Securities ........................................................................................................................ 15
Item 18 – Financial Information ............................................................................................................................ 15
Form ADV Part 2B – Brochure Supplements ...................................................................................................... 16
Privacy Policy......................................................................................................................................................... 25
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 3
https://harrellpartners.com
Item 4 – Advisory Services
A. Firm Information
Harrell Investment Partners, LLC (“HIP” or the “Advisor”) is a registered investment advisor with the U.S. Securities
and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (LLC) under the laws
of the State of Texas. HIP was founded in September 2018 and is owned by Robert K. Harrell II (Principal). The
Chief Compliance Officer of HIP is Dilda Dalvi. This Disclosure Brochure provides information regarding the
qualifications, business practices, and the advisory services provided by HIP.
B. Advisory Services Offered
HIP offers investment advisory services to individuals, high net worth individuals, and charitable organizations
(each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. HIP's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Investment Management Services
HIP provides customized investment advisory solutions for its Clients. This is achieved through continuous personal
Client contact and interaction while providing discretionary and non-discretionary investment management and
continuous financial planning services. HIP utilizes a four-step approach to help ensure it fully understands and
addresses client needs while providing flexibility to its clients with respect to their investment needs.
● Discover: HIP will first spend time with the client, asking questions, discussing the Client’s financial situation
and investment experience, and broadly identifying major goals of the Client.
● Design: HIP will review and analyze the information provided by the Client. Based on its reviews, HIP
generally develops with each Client:
o a financial outline for the Client based on the Client’s financial situation and goals, and the client’s
risk tolerance level (the “Financial Profile”); and
o
the Client’s investment objectives and guidelines (the “Investment Plan”).
The Financial Profile is a reflection of the Client’s current financial picture and a look to the future goals of
the Client. The Investment Plan outlines the types of investments HIP will make or recommend on behalf of
the Client based on HIP’ own research and analysis in order to meet those goals. The elements of the
Financial Profile and the Investment Plan are discussed periodically with each Client, but are not necessarily
written documents. The Investment Plan will be updated from time to time when requested by the Client, or
when determined to be necessary or advisable by HIP based on updates to the Client’s financial or other
circumstances.
●
Implement: To execute the Client’s Investment Plan, HIP will manage the Client’s investment portfolio on
a discretionary or a non-discretionary basis pursuant to an investment advisory agreement with the Client.
As a discretionary investment adviser, HIP will have the authority to supervise and direct the portfolio without
prior consultation with the Client.
Clients who choose a non-discretionary arrangement must be contacted prior to the execution of any trade
in the account(s) under management. This may result in a delay in executing recommended trades, which
could adversely affect the performance of the portfolio. This delay also normally means the affected
account(s) will not be able to participate in block trades, a practice designed to enhance the execution
quality, timing and/or cost for all accounts included in the block. In a non-discretionary arrangement, the
Client retains the responsibility for the final decision on all actions taken with respect to the portfolio.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 4
https://harrellpartners.com
Manage: HIP will monitor the investment performance of Client accounts relative to their Financial Profiles
on an ongoing basis.
Notwithstanding the foregoing, Clients may impose certain written restrictions on HIP in the management of their
investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or
prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each Client
should note, however, that restrictions imposed by a Client may adversely affect the composition and performance
of the Client’s investment portfolio. Each Client should also note that his or her investment portfolio is treated
individually by giving consideration to each purchase or sale for the Client’s account. For these and other reasons,
performance of Client investment portfolios within the same investment objectives, goals and/or risk tolerance may
differ and Clients should not expect that the composition or performance of their investment portfolios would
necessarily be consistent with similar Clients of HIP. The Advisor may retain other types of investments from the
Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified
between the Advisor and the Client.
Retirement Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a Client
take a distribution from an ERISA sponsored plan or to roll over the assets to an Individual Retirement Accounts
(“IRAs”), or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one
IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based
account). In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The
Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as
applicable, which are laws governing retirement accounts. Such a recommendation creates a conflict of interest if
the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under
any obligation to roll over a retirement account to an account managed by the Advisor.
At no time will HIP accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Financial Planning Services - HIP will typically provide a variety of continuous financial planning services. Such
services may be included in the overall advisory services or contracted separately, based on the Client’s needs and
complexity of the services to be provided. Services are offered in several areas of a Client’s financial situation,
depending on their goals and objectives. Generally, such financial planning services involve preparing a formal
financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This
planning may encompass one or more areas of need, including but not limited to, investment planning, retirement
planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation.
Depending on a Client’s particular situation, financial planning services may include some or all of the following:
● Gathering factual information concerning the Client’s personal and financial situation;
● Assisting the Client in establishing financial goals and objectives;
● Analyzing the Client’s present situation and anticipated future activities in light of the Client's financial goals
●
and objectives;
Identifying problems foreseen in the accomplishment of these financial goals and objectives and offering
alternative solutions to the problems;
● Making recommendations to help achieve retirement plan goals and objectives;
● Designing an investment portfolio to help meet the goals and objectives of the Client;
● Providing estate planning;
● Assessing risk and reviewing basic health, life and disability insurance needs; or
● Reviewing goals and objectives and measuring progress toward these goals.
HIP may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation.
For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial
situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 5
https://harrellpartners.com
a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming
all information and documents requested are provided promptly.
Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the
Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment
management services or to increase the level of investment assets with the Advisor, as it would increase the
amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by
the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the
recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the
Advisor.
Separate Account Managers - HIP may select one or more Separate Account Managers (each, a “Manager”)
through a wrap program sponsored by Raymond James & Associates member New York Stock Exchange/SIPC
(the “Raymond James Wrap Program”) to act as a sub-adviser for Client accounts. HIP’s access to various
Managers allows HIP to offer a wide variety of manager styles, and provides the opportunity to utilize more than
one Manager. Factors that HIP considers in recommending/selecting a Manager for a client account generally
include the client’s stated investment objective(s), management style, performance, risk level, reputation, financial
strength, reporting, pricing, and research.
The Manager(s) generally will be granted discretionary trading authority to provide investment supervisory services
for the portfolio. In most cases, HIP retains the authority to terminate the Manager’s relationship or to add new
Managers without specific client consent. HIP will monitor the investment approach and performance of the
Manager(s).
C. Client Account Management
Prior to engaging HIP to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
● Establishing an Investment Strategy – HIP, in connection with the Client, will develop a strategy that seeks
to achieve the Client’s goals and objectives.
● Asset Allocation – HIP will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
● Portfolio Construction – HIP will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
●
Investment Management and Supervision – HIP will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
HIP does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by HIP.
E. Assets Under Management
As of December 31, 2024, HIP manages $598,645,365 in Client assets, $572,083,560 of which are managed on a
discretionary basis and $26,561,805 on a non-discretionary basis. Clients may request more current information at
any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one more
written agreements with the Advisor.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 6
https://harrellpartners.com
A. Fees for Advisory Services
Investment Management Services
Investment advisory fees are paid in advance of each calendar quarter pursuant to the terms of the investment
advisory agreement. Investment advisory fees are based on the market value of assets under management at the
end of the prior calendar quarter. Investment advisory fees range from up to 1.25% annually based on several
factors, including: the scope and complexity of the services to be provided; the level of assets to be managed; and
the overall relationship with the Advisor. The minimum annual fee for any account is $10,000. The Advisor may, in
its discretion, make exceptions to the foregoing or negotiate special fee arrangements where HIP deem it
appropriate under the circumstances. Relationships with multiple objectives, specific reporting requirements,
portfolio restrictions and other complexities may be charged a higher fee.
The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the
end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed
by HIP will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s
valuations to ensure accurate billing.
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and
other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the
Advisor shall not receive any portion of these commissions, fees, and costs.
Financial Planning Services
HIP offers stand-alone financial planning services either on an hourly or fixed fee basis. Fees may be negotiable
based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An
estimate for total hours and/or total costs will be provided to the Client prior to engaging for these services.
Separate Account Manager Fees
For Clients referred by the Advisor to a Manager[s], the Client’s fee may be separately billed or deducted from the
Client’s account[s] by the Manager[s].
HIP will have an apparent or actual conflict of interest to select Managers with lower fees than other Managers,
because HIP retains the portion of its fee not paid to Managers. However, HIP will select Managers in the best
interest of its Clients. With respect to the Raymond James Wrap Program, HIP generally pays a fixed portion of its
fee to the Managers in the Raymond James Wrap Program and retains the remainder of the investment advisory
fees charged, which is subject to a maximum of 1.25%.
B. Fee Billing
Investment Management Services
Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at
the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted
from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying
the quarterly rate (annual rate divided by 4) to the total assets under management with HIP at the end of the prior
quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the
investment advisory fee. Clients are urged to also review and compare the statement provided by the Advisor to the
brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide
written authorization permitting advisory fees to be deducted by HIP to be paid directly from their account[s] held by
the Custodian as part of the investment advisory agreement and separate account forms provided by the
Custodian.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 7
https://harrellpartners.com
Financial Planning Services
Financial planning fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the
financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s].
Separate Account Manager Fees
For Clients referred by the Advisor to a Manager[s], the Client’s fee may be separately billed or deducted from the
Client’s account[s] with the respective manager and a portion of the investment advisory fee may be provided to
HIP.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than HIP, in connection with investments
made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees
charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities
transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and
conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds
and other types of investments. The fees charged by HIP are separate and distinct from these custody and
execution fees.
In addition, all fees paid to HIP for investment advisory services are separate and distinct from the expenses
charged by mutual funds and ETFs to their shareholders, if applicable. The Advisor's recommended Custodian
does not charge securities transaction fees for ETF and equity trades in Client accounts, but typically charges for
mutual funds and other types of investments. These fees and expenses are described in each fund’s prospectus.
These fees and expenses will generally be used to pay management fees for the funds, other fund expenses,
account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client
may be able to invest in these products directly, without the services of HIP, but would not receive the services
provided by HIP which are designed, among other things, to assist the Client in determining which products or
services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should
review both the fees charged by the fund[s] and the fees charged by HIP to fully understand the total fees to be
paid. Please refer to Item 12 – Brokerage Practices for additional information.
D. Advance Payment of Fees and Termination
Investment Management Services
HIP may be compensated for its investment management services in advance of the quarter in which services are
rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written
notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business
days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur
charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable
by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the
effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor
is non-transferable without the Client’s prior consent.
Financial Planning Services
HIP requires an advance deposit as described above. Either party may terminate the financial planning agreement,
at any time, by providing advance written notice to the other party. The Client may also terminate the financial
planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After
the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination
and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours
logged on the planning project times the contractual hourly rate or in the case of a fixed fee engagement, the
percentage of the engagement scope completed by the Advisor. Upon termination, the Advisor will refund any
unearned, prepaid planning fees from the effective date of termination to the end of the quarter. The Client’s
financial planning agreement with the Advisor is non-transferable without the Client’s prior consent.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 8
https://harrellpartners.com
Separate Account Manager Fees
In the event that a Client should wish to terminate their relationship with the Independent Manager, the terms for
termination will be set forth in the respective agreements between the Client and that Independent Manager. HIP
will assist the Client with the termination and transition as appropriate.
E. Compensation for Sales of Securities
HIP does not buy or sell securities to earn commissions and does not receive any compensation for securities
transactions in any Client account, other than the investment advisory fees noted above.
Certain Advisory Persons are licensed as independent insurance professionals. These persons will earn
commission-based compensation for selling insurance products, including insurance products they sell to Clients.
Insurance commissions earned by these persons are separate and in addition to advisory fees. This practice
presents a conflict of interest because persons providing investment advice on behalf of the Advisor who are
insurance agents have an incentive to recommend insurance products to Clients for the purpose of generating
commissions rather than solely based on Client needs. However, Clients are under no obligation, contractually or
otherwise, to purchase insurance products through any person affiliated with the Advisor. Please see item 10 –
Other Financial Industry Activities and Affiliations.
Item 6 – Performance-Based Fees and Side-By-Side Management
HIP does not charge performance-based fees for its investment advisory services. The fees charged by HIP are as
described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any
Client.
HIP does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a
hedge fund) and has no financial incentive to recommend any particular investment options to its Clients.
Item 7 – Types of Clients
HIP offers investment advisory services to individuals, high net worth individuals and charitable organizations. The
amount of each type of Client is available on HIP’s Form ADV Part 1A. These amounts may change over time and
are updated at least annually by the Advisor. HIP generally does not impose a minimum relationship size.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
HIP employs fundamental, technical, cyclical, charting and quantitative analysis methods in developing investment
strategies for its Clients. Research and analysis from HIP are derived from numerous sources, including financial
media companies, third-party research materials, Internet sources, and review of company activities, including
annual reports, prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria
consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being
analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with
a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment,
it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in
the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors
these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the
Advisor’s review process are included below in Item 13 – Review of Accounts.
Technical analysis involves the analysis of past market data rather than specific company data in determining the
recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and
trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk
in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 9
https://harrellpartners.com
the trend will eventually reoccur, there is no guarantee that HIP will be able to accurately predict such a
reoccurrence.
Cyclical analysis is similar to technical analysis in that it involves the analysis of market conditions at a macro
(entire market/economy) or micro (company specific) level, rather than the overall fundamental analysis of the
health of the particular company that HIP is recommending. The risks with cyclical analysis are similar to those of
technical analysis.
Charting analysis utilizes various market indicators as investment selection criteria. These criteria are generally
pricing trends that may indicate movement in the markets. Assets are deemed suitable if they meet certain criteria
to indicate that they are a strong investment with a value discounted by the market. While this type of analysis
helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in
value. Assets meeting the investment criteria utilized in the technical and charting analysis may lose value and may
have negative investment performance. The Advisor monitors these market indicators to determine if adjustments
to strategic allocations are appropriate.
Qualitative analysis involves analysis that uses subjective judgment based on unquantifiable information, such as
management expertise, industry cycles, strength of research and development. Qualitative analysis contrasts with
quantitative analysis, which focuses on numbers such as the firm’s financials and prospectus or offering
memorandums. Both techniques are often used together in order to examine a company’s operations and evaluate
its potential as an investment opportunity.
As noted above, HIP generally employs a long-term investment strategy for its Clients, as consistent with their
financial goals. HIP will typically hold all or a portion of a security for more than a year, but may hold for shorter
periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, HIP may also buy
and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals
of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. HIP will assist Clients in determining an appropriate strategy
based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will
meet their investment goals. Please see Item 8.B. for risks associated with the Advisor’s investment strategies as
well as general risks of investing.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may
lose value and may have negative investment performance. The Advisor monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are
included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction
process. Following are some of the risks associated with the Advisor’s investment strategies:
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 10
https://harrellpartners.com
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk
based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-
ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may
dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased
or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same
price as a mutual fund purchased later that same day.
Options Contracts
Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts
are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock.
This leverage can compound gains or losses.
Alternative Investments (Limited Partnerships)
The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An
investor could lose all or a portion of their investment. Such investments often have concentrated positions and
investments that may carry higher risks. Client should only have a portion of their assets in these investments.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving HIP or its management person[s]. HIP values
the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any
advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are
available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the
Advisor’s firm name or CRD# 299166.
Item 10 – Other Financial Industry Activities and Affiliations
Insurance Agency Affiliations
As noted in Item 5, Advisory Persons are also licensed insurance professionals. Implementations of insurance
recommendations are separate and apart from one’s role with HIP. As an insurance professional, an Advisory
Person will receive customary commissions and other related revenues from the various insurance companies
whose products are sold. Advisory Persons are not required to offer the products of any particular insurance
company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a
conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to
implement any recommendations made by Advisory Persons or the Advisor.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 11
https://harrellpartners.com
Separate Account Managers
As noted in Item 4, the Advisor may select Manager[s] to assist with the implementation of a Client’s investment
strategy. In such arrangements, the Advisor will receive a portion of the investment advisory fees collected by the
Manager[s] from the Client. The Advisor will not charge its own investment advisory fee for assets referred to an
Manager[s].
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
HIP has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client.
This Code applies to all persons associated with HIP (“Supervised Persons”). The Code was developed to provide
general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. HIP and its
Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of HIP’s
Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that
guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To
request a copy of the Code, please contact the Advisor at (512) 759-8000 or via email at dee@harrellpartners.com.
B. Personal Trading with Material Interest
HIP allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. HIP does not act as principal in any transactions. In addition, the Advisor does not
act as the general partner of a fund, or advise an investment company. HIP does not have a material interest in any
securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
HIP allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and
procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public
information controls); gifts and entertainment; outside business activities and personal securities reporting. When
trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The
fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is
mitigated by HIP requiring reporting of personal securities trades by its Supervised Persons for review by the Chief
Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect
the misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While HIP allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no
time will HIP, or any Supervised Person of HIP, transact in any security to the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
HIP does not have discretionary authority to select the broker-dealer/custodian for custody and execution services.
The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and
authorize HIP to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, HIP
does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis.
Under certain instances, the Client may grant the Advisor limited authority to place trades away from the Custodian.
Please see Prime Brokerage Authorization below.
Where HIP does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to
Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 12
https://harrellpartners.com
not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by HIP.
However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged.
HIP may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions
charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s
offices.
HIP will generally recommend that Clients establish their account[s] at Raymond James & Associates, Inc.
(“Raymond James”), a FINRA-registered broker-dealer and member New York Stock Exchange/SIPC. Raymond
James will serve as the Client’s “qualified custodian”. HIP maintains an institutional relationship with Raymond
James, whereby the Advisor receives economic benefits from Raymond James. Please see Item 14 below.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and
other services. HIP does not participate in soft dollar programs sponsored or offered by any broker-
dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see
Item 14 below.
2. Brokerage Referrals - HIP does not receive any compensation from any third party in connection with the
recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where HIP will place trades within
the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within
their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from
or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into
one Client account from another Client’s account[s]). HIP will not be obligated to select competitive bids on
securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs
are determined by the Custodian.
4. Prime Brokerage - The Advisor may execute securities transactions either through the Custodian or through
another unaffiliated broker-dealer in connection with a prime brokerage relationship established with the Custodian.
Should a Client’s account[s] make use of prime brokerage, the Client is required to execute additional agreement[s]
with the Custodian authorizing the Advisor to trade-away from and settle to the Client’s established account[s] at
the Custodian. The Custodian may charge an additional trade-away fee for these transactions in addition to the
normal securities transaction costs.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution,
4) confidentiality and 5) skill required of the Custodian. HIP will execute its transactions through the Custodian as
authorized by the Client. HIP may aggregate orders in a block trade or trades when securities are purchased or
sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be
executed in full at the same price or time, the securities actually purchased or sold by the close of each business
day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This
must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Dilda Dalvi, Chief Compliance
Officer of HIP. Formal reviews are generally conducted at least annually or more frequently depending on the
needs of the Client.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 13
https://harrellpartners.com
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result
of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or
withdrawals in the Client’s account[s]. The Client is encouraged to notify HIP if changes occur in the Client’s
personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be
triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the
Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also
provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by HIP
HIP may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate
planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, HIP may receive
non-compensated referrals of new Clients from various third-parties.
Participation in Institutional Advisor Platform
HIP has established an institutional relationship with Raymond James to assist the Advisor in managing Client
account[s]. Access to the Raymond James platform is provided at no charge to the Advisor. The Advisor receives
access to software and related support without cost because the Advisor renders investment management services
to Clients that maintain assets at Raymond James. The software and related systems support may benefit the
Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the
interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a
Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this
Custodian over one that does not furnish similar software, systems support, or services.
Additionally, the Advisor has the following benefits from Raymond James: financial support, financing services,
receipt of duplicate Client confirmations and bundled duplicate statements; access to a trading desk that exclusively
services its institutional participants; access to block trading which provides the ability to aggregate securities
transactions and then allocate the appropriate shares to Client accounts; and access to an electronic
communication network for Client order entry and account information.
Use of Independent Managers
The Advisor may be indirectly compensated by a Manager[s] as described in Item 5 above and does not receive
any other forms of compensation with such arrangements.
B. Client Referrals from Promoters
The Advisor does not compensate, either directly or indirectly, any affiliated or unaffiliated parties (“Promoters”) for
Client referrals.
Item 15 – Custody
HIP does not accept or maintain custody of Client accounts, except for the limited circumstances outlined below:
Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of
advisory fees, all Clients for whom HIP exercises discretionary authority must hold their assets with a "qualified
custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 14
https://harrellpartners.com
must instruct HIP to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to
review statements provided by the Custodian and compare to any reports provided by HIP to ensure accuracy, as
the Custodian does not perform this review.
Money Movement Authorization - For instances where Clients authorize HIP to move funds between their accounts,
HIP and the Custodian have implemented safeguards to ensure that all money movement activities are conducted
strictly in accordance with the Client’s documented instructions.
Item 16 – Investment Discretion
HIP generally has discretion over the selection and amount of securities to be bought or sold in Client accounts
without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to
specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by HIP.
Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will
be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to
such authority. All discretionary trades made by HIP will be in accordance with each Client's investment objectives
and goals.
In certain circumstances, HIP does not have discretion over the selection and amount of securities to be bought or
sold in Client accounts without obtaining prior approval from the Client. The Advisor will contact the Client and
obtain approval prior to executing trades or allocating investment assets.
Item 17 – Voting Client Securities
HIP does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the
Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole
responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither HIP, nor its management, have any adverse financial situations that would reasonably impair the ability of
HIP to meet all obligations to its Clients. Neither HIP, nor any of its Advisory Persons, have been subject to a
bankruptcy or financial compromise. HIP is not required to deliver a balance sheet along with this Disclosure
Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months
or more in the future.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 15
https://harrellpartners.com
Form ADV Part 2B – Brochure Supplement
for
Robert K. Harrell
Founder
Effective: December 23, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Robert K. Harrell (CRD# 2282318) in addition to the information contained in the Harrell Investment Partners, LLC
(“HIP” or the “Advisor”, CRD# 299166) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the HIP Disclosure Brochure or this Brochure
Supplement, please contact the Advisor at (512) 759-8000 or by email at dee@harrellpartners.com.
Additional information about Mr. Harrell is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2282318.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 16
https://harrellpartners.com
Item 2 – Educational Background and Business Experience
Robert K. Harrell, born in 1965, is dedicated to advising Clients of HIP as Founder. Mr. Harrell earned a BA,
Economics from University of Texas in 1987. Additional information regarding Mr. Harrell’s employment history is
included below.
Employment History:
Founder, Harrell Investment Partners, LLC
Managing Director, Raymond James & Associates, Inc
01/2019 to Present
05/1989 to 12/2018
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Harrell. Mr. Harrell has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Harrell.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Harrell.
However, we do encourage you to independently view the background of Mr. Harrell on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
2282318.
Item 4 – Other Business Activities
Mr. Harrell is dedicated to the investment advisory activities of HIP’s Clients. Mr. Harrell does not have any other
business activities.
Item 5 – Additional Compensation
Mr. Harrell is dedicated to the investment advisory activities of HIP’s Clients. Mr. Harrell does not receive any
additional forms of compensation.
Item 6 – Supervision
Mr. Harrell serves as the Founder of HIP and is supervised by Dilda Dalvi, the Chief Compliance Officer. Ms. Dalvi
can be reached at (512) 759-8000.
HIP has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of HIP. Further, HIP is subject to regulatory oversight by various
agencies. These agencies require registration by HIP and its Supervised Persons. As a registered entity, HIP is
subject to examinations by regulators, which may be announced or unannounced. HIP is required to periodically
update the information provided to these agencies and to provide various reports regarding the business activities
and assets of the Advisor.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 17
https://harrellpartners.com
Form ADV Part 2B – Brochure Supplement
for
Anna V. Bodine, CFP®
Chief Operating Officer/Partner
Effective: December 23, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Anna
V. Bodine, CFP®, (CRD# 5217850) in addition to the information contained in the Harrell Investment Partners, LLC
(“HIP” or the “Advisor”, CRD# 299166) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the HIP Disclosure Brochure or this Brochure
Supplement, please contact the Advisor at (512) 759-8000 or by email at dee@harrellpartners.com.
Additional information about Mrs. Bodine is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 5217850.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 18
https://harrellpartners.com
Item 2 – Educational Background and Business Experience
Anna V. Bodine, CFP®, born in 1974, is dedicated to advising Clients of HIP as the Chief Operating Officer/Partner.
Mrs. Bodine earned a Bachelor of Arts in Organizational Leadership from St. Edward's University in 2016.
Additionally, Mrs. Bodine was a candidate for a Bachelor of Nursing Degree from the University of Texas. Additional
information regarding Mrs. Bodine’s employment history is included below.
Employment History:
Chief Operating Officer/Partner, Harrell Investment Partners, LLC
Chief Operating Officer/Senior Advisor, Harrell Investment Partners, LLC
Branch Manager, Raymond James & Associates, Inc.
03/2024 to Present
01/2019 to 03/2024
10/2010 to 01/2019
Certified Financial Planner™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners
to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 71,000 individuals have
obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP® Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally
accredited United States college or university (or its equivalent from a foreign university). CFP® Board’s
financial planning subject areas include insurance planning and risk management, employee benefits
planning, investment planning, income tax planning, retirement planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case
studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues
and apply one’s knowledge of financial planning to real world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements
in order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary standard
of care. This means CFP® professionals must provide financial planning services in the best interests of
their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP®
Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®
certification.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 19
https://harrellpartners.com
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mrs. Bodine. Mrs. Bodine has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mrs. Bodine.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mrs. Bodine.
However, we do encourage you to independently view the background of Mrs. Bodine on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD#
5217850.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mrs. Bodine is also a licensed insurance professional. Implementations of insurance recommendations are
separate and apart from Mrs. Bodine’s role with HIP. As an insurance professional, Mrs. Bodine will receive
customary commissions and other related revenues from the various insurance companies whose products are
sold. Mrs. Bodine is not required to offer the products of any particular insurance company. Commissions
generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in
recommending certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by Mrs. Bodine or the Advisor. Mrs. Bodine spends approximately 1% of her time per
month in this capacity.
Item 5 – Additional Compensation
Mrs. Bodine has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mrs. Bodine serves as the Chief Operating Officer/Partner of HIP and is supervised by Dilda Dalvi, the Chief
Compliance Officer. Ms. Dalvi can be reached at (512) 759-8000.
HIP has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of HIP. Further, HIP is subject to regulatory oversight by various
agencies. These agencies require registration by HIP and its Supervised Persons. As a registered entity, HIP is
subject to examinations by regulators, which may be announced or unannounced. HIP is required to periodically
update the information provided to these agencies and to provide various reports regarding the business activities
and assets of the Advisor.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 20
https://harrellpartners.com
Form ADV Part 2B – Brochure Supplement
for
Dilda D. Dalvi
Chief Compliance Officer
Senior Vice President of Operations
Effective: December 23, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Dilda
D. Dalvi (CRD# 4850130) in addition to the information contained in the Harrell Investment Partners, LLC (“HIP” or
the “Advisor”, CRD# 299166) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if
you have any questions about the contents of the HIP Disclosure Brochure or this Brochure Supplement, please
contact us at (512) 759-8007.
Additional information about Ms. Dalvi is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 4850130.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 21
https://harrellpartners.com
Item 2 – Educational Background and Business Experience
Dilda D. Dalvi, born in 1972, is dedicated to advising Clients of HIP as the Chief Compliance Officer and Senior
Vice President of Operations. Ms. Dalvi earned a Bachelor’s Degree in Economics and Accounting from Karnataka
University in 1994. Additional information regarding Ms. Dalvi’s employment history is included below.
Employment History:
11/2020 to Present
08/2021 to 11/2021
03/2020 to 07/2021
Chief Compliance Officer and Senior Vice President of Operations, Harrell
Investment Partners, LLC
Investment Advisor Representative, Live Oak Investment Partners, LLC
Branch Administrator, Raymond James Financial Services - Ciani Thomas
Financial
Senior Registered CSA, Raymond James & Associates
Branch Liaison, Wells Fargo Advisors LLC
03/2017 to 12/2019
06/2013 to 05/2015
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Ms. Dalvi. Ms. Dalvi has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Ms. Dalvi.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Ms. Dalvi.
However, we do encourage you to independently view the background of Ms. Dalvi on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD#
4850130.
Item 4 – Other Business Activities
Position / Dispute Resolution Arbitrator
Ms. Dalvi serves as a Position / Dispute Resolution Arbitrator for FINRA. Ms. Dalvi spends approximately 10 hours
per month in her capacity as a Position / Dispute Resolution Arbitrator.
Item 5 – Additional Compensation
Ms. Dalvi has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Ms. Dalvi serves as Chief Compliance Officer and Vice President of Operations of HIP. Ms. Dalvi can be reached at
(512) 759-8000.
HIP has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of HIP. Further, HIP is subject to regulatory oversight by various
agencies. These agencies require registration by HIP and its Supervised Persons. As a registered entity, HIP is
subject to examinations by regulators, which may be announced or unannounced. HIP is required to periodically
update the information provided to these agencies and to provide various reports regarding the business activities
and assets of the Advisor.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 22
https://harrellpartners.com
Form ADV Part 2B – Brochure Supplement
for
Stephanie C. Morgan
Director of Investment Strategy
Effective: December 23, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Stephanie C. Morgan (CRD# 8064296) in addition to the information contained in the Harrell Investment Partners,
LLC (“HIP” or the “Advisor”, CRD# 299166) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the HIP Disclosure Brochure or this Brochure
Supplement, please contact us at (512) 759-8000.
Additional information about Ms. Morgan is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 8064296.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 23
https://harrellpartners.com
Item 2 – Educational Background and Business Experience
Stephanie C. Morgan, born in 1996, is dedicated to advising Clients of HIP as the Director of Investment Strategy.
Ms. Morgan earned a BBA in Finance from the University of Texas at Austin in 2020. Additional information
regarding Ms. Morgan’s employment history is included below.
Employment History:
Director of Investment Strategy, Harrell Investment Partners, LLC
Analyst - Corporate Finance & Treasury, Petros PACE Finance
Data Analytics Intern, GoMedigap
05/2023 to Present
10/2020 to 04/2023
06/2019 to 08/2019
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Ms. Morgan. Ms. Morgan has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Ms. Morgan.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Ms. Morgan.
However, we do encourage you to independently view the background of Ms. Morgan on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD#
8064296.
Item 4 – Other Business Activities
Ms. Morgan is dedicated to the investment advisory activities of HIP’s Clients. Ms. Morgan does not have any other
business activities.
Item 5 – Additional Compensation
Ms. Morgan is dedicated to the investment advisory activities of HIP’s Clients. Ms. Morgan does not receive any
additional forms of compensation.
Item 6 – Supervision
Ms. Morgan serves as the Director of Investment Strategy of HIP and is supervised by Dilda Dalvi, the Chief
Compliance Officer. Ms. Dalvi can be reached at (512) 759-8000.
HIP has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of HIP. Further, HIP is subject to regulatory oversight by various
agencies. These agencies require registration by HIP and its Supervised Persons. As a registered entity, HIP is
subject to examinations by regulators, which may be announced or unannounced. HIP is required to periodically
update the information provided to these agencies and to provide various reports regarding the business activities
and assets of the Advisor.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 24
https://harrellpartners.com
Privacy Policy
Effective: December 23, 2025
Our Commitment to You
Harrell Investment Partners, LLC (“HIP” or the “Advisor”) is committed to safeguarding the use of personal
information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as
described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your private
information, and we do everything that we can to maintain that trust. HIP (also referred to as "we", "our" and "us”)
protects the security and confidentiality of the personal information we have and implements controls to ensure that
such information is used for proper business purposes in connection with the management or servicing of our
relationship with you.
HIP does not sell your non-public personal information to anyone. Nor do we provide such information to others
except for discrete and reasonable business purposes in connection with the servicing and management of our
relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth
in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Account applications and forms
Investment questionnaires and suitability
documents
Transactional information with us or others
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal information
and have policies over the transmission of data. Our associates are trained on their responsibilities to protect
Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they receive
from us.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 25
https://harrellpartners.com
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including but
not limited to: processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
No
Not Shared
Marketing Purposes
HIP does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with
financial institutions where you are a customer and where HIP or the
client has a formal agreement with the financial institution. We will only
share information for purposes of servicing your accounts, not for
marketing purposes.
Yes
Yes
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
No
Not Shared
Information About Former Clients
HIP does not disclose and does not intend to disclose, non-public
personal information to non-affiliated third parties with respect to persons
who are no longer our Clients.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal
information other than as described in this notice unless we first notify you and provide you with an opportunity to
prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting
us at (512) 759-8000 or via email at dee@harrellpartners.com.
Harrell Investment Partners, LLC
3814 Medical Parkway, Austin, TX 78756
Phone: (512) 759-8000 * Fax: (512) 759-8100
Page 26
https://harrellpartners.com