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6116 Harrison Avenue Cincinnati, Ohio 45247
Part 2A of Form ADV
Firm Brochure
February 12, 2026
Phone:
513.598.5120
Email:
info@hcmwealthadvisors.com
Website: hcmwealthadvisors.com
Part 2A of Form ADV: Firm Brochure
This Brochure provides information about the qualifications and business practices of Hengehold Capital
Management LLC dba HCM Wealth Advisors. If you have any questions about the contents of this
Brochure, please contact us at 513.598.5120 or info@HCMWealthAdvisors.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.
HCM Wealth Advisors is a registered investment adviser. Registration of an investment adviser does not
imply any level of skill or training.
Additional information about HCM Wealth Advisors also is available on the SEC’s website at
www.adviserinfo.sec.gov. HCM Wealth Advisors’ CRD number is 107700.
Item 2
Summary of Material Changes
There have been no material changes since the February 20, 2025, Form ADV filed on the IARD system.
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Item 3
Table of Contents
ADV Part 2A
Page
Item 1
Cover Page
Item 2
Summary of Material Changes
1
Item 3
Table of Contents
2
Item 4
Advisory Business
3
Item 5
Fees and Compensation
4
Item 6
Performance-Based Fees and Side-By-Side Management
5
Item 7
Types of Clients
5
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
6
Item 9
Disciplinary Information
7
Item 10
Other Financial Industry Activities and Affiliations
7
Item 11
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
8
Item 12
Brokerage Practices
9
Item 13
Review of Accounts
11
Item 14
Client Referrals and Other Compensation
11
Item 15
Custody
11
Item 16
Investment Discretion
12
Item 17
Voting Client Securities
12
Item 18
Financial Information
12
Privacy Policy
12
Form ADV Part 2b for Each Supervised Person
14
2
Item 4 Advisory Business
Hengehold Capital Management LLC dba HCM Wealth Advisors (HCM Wealth Advisors) was organized
in 1990 and is a Registered Investment Adviser with the SEC with its principal place of business located
in Ohio. The Firm's majority owner is Michael Hengehold. HCM Wealth Advisors is a fiduciary and is
required to act in a client’s best interest at all times.
Individual Portfolio Management: HCM Wealth Advisors provides continuous management to our
clients regarding the investment of their funds. Working with the client, we establish an investment policy
(stated in the client’s management agreement as a neutral asset allocation target) and create and
manage a portfolio based on that policy. During our data-gathering process, we review the client’s
individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review
and discuss a client's prior investment history.
We manage these advisory accounts on a discretionary basis. Discretionary means the trading activity
with your account is directed by us without receiving prior authorization. Discretion grants Advisor the
authority to implement asset allocation changes that may be substantially different than the clients’
neutral allocation target, based on Advisor’s opinion of investment risk and/or opportunity.
Clients retain ownership of all securities.
Our investment recommendations include, but are not limited to advice regarding the following securities:
• Certificates of deposit
• Commercial paper
• Corporate debt securities
• Exchange-listed securities (Stocks and ETFs)
• Foreign issuers
• Municipal securities
• Mutual fund shares
• Options contracts on securities
• United States government securities
• Variable annuities
• Warrants
Because some types of investments involve certain additional degrees of risk, they will only be utilized
when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability.
Advisor will, with certain limited exceptions, determine the portfolio holdings to be utilized. HCM Wealth
Advisors’ investment style is long-term and should be evaluated over full market cycles.
Our Firm provides portfolio management services to clients using model based asset allocation portfolios.
Each model portfolio is based on risk and return assumptions developed by reference to long term
historical observations that may or may not repeat in the future. Portfolio results should not be
considered a predictor of future results.
Through discussions with the client, we establish portfolio goals and objectives. We help the client decide
which model portfolio is suitable based on the client's circumstances and what customization may be
appropriate. Once the suitability of the portfolio has been determined, the portfolio is managed based on
the model’s goal, with client specific modifications based on unique cash flow needs. Clients may decline
to implement any advice rendered.
To confirm that the initial determination of an appropriate portfolio remains suitable and that the account
continues to be managed in a manner consistent with the client's financial circumstances, we will:
1. Periodically contact each client to ask if there have been any changes in the client's financial
situation or investment objectives,
2. Ask if the client wishes to impose investment restrictions or modify existing restrictions;
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3. Be available to meet with the client at their convenience.
Selection and Monitoring of Third-Party Money Managers and Sub-Advisers:
Some clients’ investment portfolios are managed by outside portfolio managers. We select and review
outside portfolio managers based on the following factors:
cost;
investment philosophy;
• past performance;
•
•
• market outlook;
• experience of portfolio managers and executive team;
• opinions of third-party analysts;
• disciplinary, legal and regulatory histories of the firm and its associates;
• whether established compliance procedures are in place to address at a minimum, insider
trading, conflicts of interest, anti-money laundering;
• proxy voting policy.
We do not calculate portfolio manager performance. Instead, we rely upon the performance figures based
on the client’s account statements or reports provided to us by the outside portfolio managers. We do,
however, watch out for several types of events in conjunction with poor performance. These events
trigger an in-depth review of an outside portfolio manager and primarily include:
• Significant changes in asset allocation;
• Substantial drift in investment style; and/or
• Sustained under-performance.
We do not verify the accuracy of such performance information or its compliance with presentation
standards. As a result, performance information may not be calculated on a uniform and consistent basis.
We can hire or delegate authority to independent third-party investment managers and sub-advisers to
manage a portion of our client's portfolio through advisory management services programs and we have
the ability to fire independent third-party managers and sub-advisers.
In addition, we offer financial planning services, schedule meetings and calls to keep the plan current and
monitor changes in your personal situation. These financial planning services are included in the portfolio
management services previously described.
HCM Wealth Advisors publishes a periodic newsletter at no charge, providing general information on
various topics. No specific investment recommendations are provided and the information is not intended
to meet the objectives or needs of any individual.
Amount Of Managed Assets As of 12/31/2025 we were actively managing $1,230,580,072 of clients'
assets on a discretionary basis.
Fees and Compensation
Item 5
The fee for the Advisory Service is based on the following schedule:
SIZE OF ACCOUNT
ANNUAL FEE
LAYER I
$0 to $1,000,000
1.00 %
LAYER II
$1,000,001 to $5,000,000
.75 %
LAYER III
OVER $5,000,000
.50 %
Existing clients may have a different fee schedule. The fees described above may be for multiple account
management services and are based on the total market value of assets under management. Fees are
deducted directly from the client's brokerage account at the beginning of each quarter. A pro rata formula
is used when establishing a new account in the middle of a quarter. Clients are billed only for the time
their assets are under management.
We retain the option to negotiate fees and compensation on a client-by-client basis. Factors to consider
may include: the complexity of the client’s situation, assets to be placed under management, anticipated
future additional assets and related accounts, among other factors. The specific annual fee schedule will
be identified in the contract between HCM Wealth Advisors and each client.
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Discounts may be offered to family members and HCM Wealth Advisors employees.
General Information Regarding Fees
Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either
party, for any reason. As disclosed above, certain fees are paid in advance of services provided. Upon
termination of any account, any prepaid unearned fees will be promptly refunded. We will pro rate the
reimbursement according to the number of days remaining in the billing period.
Mutual Fund Fees: All fees paid to HCM Wealth Advisors for investment advisory services are separate
and distinct from the fees and expenses charged by mutual funds and/or ETFs to their shareholders.
These fees and expenses are described in each fund's prospectus. These fees will generally include a
management fee, other fund expenses, and a possible distribution fee. A client could invest in a mutual
fund or ETF directly, without our services. In that case, the client would not receive the services which
may be provided by our Firm which are designed to assist the client with strategic and tactical asset
allocation, cash flow planning, financial independence studies, retirement planning services and
determining which securities are most appropriate for each client's financial condition and objectives.
Clients should review the fees charged by the funds and our fees to fully understand the total amount to
be paid by the client for the advisory services being provided.
Separately Managed Account Fees: Clients participating in separately managed account programs will
be charged fees by third-party money managers or sub-advisers, in addition to the advisory fee charged
by our Firm.
Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees
and expenses, if any, charged by custodians and imposed by broker dealers, including, but not limited to,
any transaction charges imposed by a broker dealer responsible for processing transactions for the
client's accounts. Please refer to Item 12 Brokerage Practices Section of this Form ADV for additional
information.
ERISA Accounts: HCM Wealth Advisors is a fiduciary to advisory clients that are employee benefit plans
or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act
(“ERISA”). As such, our Firm is subject to specific duties and obligations under ERISA and the Internal
Revenue Code that include among other things, restrictions concerning certain forms of compensation.
To avoid engaging in prohibited transactions, HCM Wealth Advisors only charges fees for investment
advice and does not accept any commission on revenue or 12b-1 fees for ERISA and Non-ERISA
accounts.
Advisory Fees in General: Clients should note that similar advisory services may or may not be
available from other registered investment advisers for similar or higher or lower fees.
Limited Prepayment of Fees: Under no circumstances do we require or solicit payment more than three
months in advance of services rendered.
Item 6
Performance-Based Fees and Side-By-Side Management
HCM Wealth Advisors does not charge performance-based fees and does not engage in side-by-side
management.
Item 7
Types of Clients
HCM Wealth Advisors provides advisory services to the following types of clients:
• High net worth individuals
• Individuals (other than high net worth individuals)
• Trusts
• Pension and profit sharing plans
• Charitable organizations
• Corporations or other businesses not listed above
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Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis: We use the following methods of analysis in formulating our investment advice
and in managing client assets:
Fundamental Analysis: We attempt to measure the intrinsic value of a security by looking at economic
and financial factors, including the overall economy, industry conditions, and the financial condition and
management of the company. These factors help us form an opinion as to whether the security is
underpriced, indicating it may be a good time to buy, or overpriced indicating it may be time to sell.
Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk,
as the price of a security can move up or down along with the overall market regardless of the economic
and financial factors considered in evaluating the security.
Asset Allocation: Rather than focusing only on security selection, we attempt to identify an appropriate
ratio of equity securities, fixed income, alternatives, and cash suitable to the client’s investment goals and
risk tolerance.
A risk of asset allocation is that the client may not participate in sharp increases in a particular security,
industry or market sector. Another risk is that the ratio of equity securities, fixed income, alternatives, and
cash will change over time due to movements in the markets and if not corrected, will no longer be
appropriate for the client’s stated goals and objectives. We periodically rebalance asset allocations to
help reduce the risk that these ratios will drift over time.
Technical Analysis: We analyze past market movements and apply that analysis to the present in an
attempt to recognize recurring patterns of investor behavior. This analysis is used to help us better
understand possible future price movements.
Technical analysis does not consider the underlying financial condition of a company. This presents a risk
in that a poorly-managed or financially unsound company may underperform regardless of market
movement.
Quantitative Analysis: We use mathematical models in an attempt to obtain measurements of a
company’s quantifiable data, such as the value of a share price or earnings per share, to better
understand the potential for changes to that data.
A risk in using quantitative analysis is that the models used may be based on assumptions that prove to
be incorrect.
Qualitative Analysis: We subjectively evaluate non-quantifiable factors such as quality of management,
labor relations, and strength of research and development factors not readily subject to measurement, to
better understand the potential for changes to share price based on that data.
A risk in using qualitative analysis is that our subjective judgment may prove incorrect.
Mutual Fund and/or ETF Analysis: We look at the experience and track record of the manager of the
mutual fund or ETF in an attempt to determine if that manager, in our opinion, has demonstrated an
above average ability to invest over a period of time and in different economic conditions. We also look at
the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in
the underlying investments held in another fund in the client’s portfolio. We also monitor the funds or
ETFs in an attempt to determine if they are continuing to follow their stated investment strategy.
A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does
not guarantee future results. A manager who has been successful may not be able to replicate that
success in the future. In addition, as we do not control the underlying investments in a fund or ETF,
managers of different funds held by the client may purchase the same security, increasing the risk to the
client if that security were to fall in value. There is also a risk that a manager may deviate from the stated
investment mandate or strategy of the fund or ETF, which could make the holding less suitable for the
client’s portfolio.
Risks Relating to All Forms of Analysis: Our securities analysis methods rely on the assumption that
the securities we purchase and sell, the rating agencies that review these securities, and other publicly-
available sources of information about these securities, are providing accurate and unbiased data. While
we attempt to be alert to indications that data may be incorrect, there is always a risk that our analysis
may be compromised by inaccurate or misleading information.
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Investment Strategies: We use the following strategies in managing client accounts, provided that such
strategies are appropriate to the needs of the client and consistent with the client's investment objectives,
risk tolerance, and time horizons, among other considerations:
Long-Term Core Portfolio Holdings: We purchase core securities with the idea of holding them in the
client's account for a year or longer. Typically, we employ this strategy when:
• we believe the securities to be currently fairly valued, and/or
• we want exposure to a particular asset class over time, regardless of the current projection for this
class.
A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not
take advantages of short-term gains that could be profitable to a client. Moreover, if our views are
incorrect, a security may decline sharply in value before we make the decision to sell.
Short-Term Tactical Holdings: We may purchase/sell securities because we believe the current cycle or
market trend favors that decision. Holding periods for tactical positions may be either short or long term,
depending on strength of the underlying trends.
Option Writing: We may use options as an investment strategy. An option is a contract that gives the
buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price
on or before a certain date. An option, just like a stock or bond, is a security which may lose value. An
option is also a derivative, because it derives its value from an underlying asset.
The two types of options are calls and puts:
• A call gives a purchaser the right to buy an asset at a certain price within a specific period of time.
We may buy a call if we believe the stock will increase in value before the option expires.
• A put gives a purchaser the right to sell an asset at a certain price within a specific period of time.
We may buy a put if we believe that the price of the stock will fall before the option expires.
We may use options or funds with similar objectives to speculate on the possibility of a price swing. We
may also use options to "hedge" a purchase of the underlying security; in other words, we may use an
option purchase to limit the potential upside and downside of a security we have purchased for a client
portfolio.
We more commonly use "covered calls", in which we sell an option on a security a client owns. In this
strategy, the client receives a premium for making the option available, and the person purchasing the
option has the right to buy the security at an agreed-upon price and date.
Risk of Loss: Securities investments are not guaranteed and you may lose money on your investments.
We ask that you work with us to help us understand your tolerance for risk.
Recommending Securities
In certain situations, we recommend investments in selected private placements or hedge funds. These
types of investments may present unique risks due to the use of leverage and potential lack of liquidity. In
addition, such recommendations may be limited only to those clients that are termed as “Accredited
Investors” as defined in Rule 205-3 of the Investment Advisers Act of 1940. These types of investments
also have varied and unique fee structures of their own. In the event we receive a portion of the fee charged
from a third-party manager, the value of a client’s assets invested with that manager will be removed from
the asset based upon which our fees are calculated and billed. Due to the unique and complex nature of
these investments, clients will receive a separate disclosure prior to any investments being made.
Item 9 Disciplinary Information
Our Firm and our employees have no disciplinary events to disclose.
Item 10 Other Financial Industry Activities and Affiliations
Neither our Firm nor our employees are engaged in other financial industry activities.
An Affiliate of the Firm, HG CPAs LLC (HG) dba HCM CPAs, provides accounting and/or tax preparation
services to clients, including clients of HCM Wealth Advisors. All such services shall be performed by
HG, in its individual professional capacity, independent of HCM Wealth Advisors, for which services HCM
Wealth Advisors shall not receive any portion of the fees charged by HG, referral or otherwise. The
members of HG, solely incidental to their respective practices as Certified Public Accountants with HG,
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may recommend HCM Wealth Advisors’ services to certain clients of HG. No client of HCM Wealth
Advisors is under any obligation to use the services of HG. HCM Wealth Advisors’ clients may receive a
discount on HG’s services. HCM Wealth Advisors Principal, Michael Hengehold, remains available to
address any questions that a client or prospective client may have regarding the above arrangement and
any corresponding perceived conflict of interest such arrangement may create. HCM Wealth Advisors
also attempts to mitigate the conflict of interest by requiring employees to acknowledge in the firm’s Code
of Ethics, their individual fiduciary duty to the clients of HCM Wealth Advisors, which requires that
employees put the interests of clients ahead of their own.
Our Firm and our employees have no other industry affiliations.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
Our Firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that
we require of our employees, including compliance with applicable federal securities laws.
HCM Wealth Advisors and our employees owe a duty of loyalty, fairness and good faith toward our
clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to
the general principles that guide the Code.
Our Code of Ethics includes policies and procedures for the quarterly review of security transaction
reports as well as initial and annual security holdings reports that must be submitted by all of the Firm’s
employees. Our code also provides for oversight, enforcement and recordkeeping provisions.
Our Code of Ethics includes the Firm's policy prohibiting the use of material non-public information. While
we do not believe that we have any particular access to non-public information, all employees are
reminded that such information may not be used in a personal or professional capacity.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request
a copy by email sent to info@hcmwealthadvisors.com, or by calling us at 513.598.5120.
HCM Wealth Advisors and individuals associated with our Firm are prohibited from engaging in principal
transactions.
Our Code of Ethics is designed to assure that the personal security transactions, activities and interests
of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii)
implementing such decisions while, at the same time, allowing employees to invest for their own
accounts.
Our Firm and the individuals associated with our Firm may buy or sell securities for their personal
accounts identical to or different from those recommended to our clients. In addition, any related person
may have an interest or position in a certain security which may also be recommended to a client.
HCM Wealth Advisors maintains an account that is owned by Michael Hengehold which represents the
Model Portfolio for the Firm’s Dividend Growth Strategy. So that the results of this model may be
accurately monitored, it is traded with (at the same time) as client accounts. It is the intent that this
account obtains the same results as clients who are invested in the same strategy.
We may aggregate our employee trades with client transactions where possible and when compliant with
our duty to seek best execution for our clients. In these instances, participating clients will receive an
average share price and transaction costs will be shared equally and on a pro-rata basis. In the instances
where there is a partial fill of a particular batched order, we will allocate all purchases on a pro-rata basis,
with each account paying the average price. Our employee accounts will be included in the pro-rata
allocation.
As these situations represent conflicts of interest to our clients, we have established the following policies
and procedures for implementing our Firm’s Code of Ethics, to ensure our Firm complies with its
regulatory obligations and provides our clients and potential clients with full and fair disclosure of such
conflicts of interest:
1. No principal or employee of our Firm may put his or her own interest above the interest of an
advisory client.
2. No principal or employee of our Firm may buy or sell securities for their personal portfolio(s) where
their decision is a result of information received as a result of his or her employment unless the
information is also available to the investing public.
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3. It is the expressed general policy of our Firm that no person employed by us may purchase or sell
any security on our restricted list prior to a transaction being implemented for a Firm wide trade.
This prevents such employee from benefiting from the potential for market moving transaction
volume placed on behalf of advisory accounts. There are some situations where exceptions are
granted. The exceptions to this policy are fully described in our Code Ethics, which is available
upon request.
4. We maintain a list of all reportable securities holdings for our Firm and anyone associated with this
advisory practice that has access to advisory recommendations ("access person"). These holdings
are reviewed on a regular basis by our Firm's Chief Compliance Officer or his designee.
5. We have established procedures for the maintenance of all required books and records.
6. All of our principals and employees must act in accordance with all applicable Federal and State
regulations governing registered investment advisory practices.
7. We require delivery and acknowledgement of the Code of Ethics by each supervised person of our
Firm. We have established policies requiring the reporting of Code of Ethics violations to our
Principal.
8. Any individual who violates any of the above restrictions may be subject to termination.
Item 12 Brokerage Practices
For discretionary relationships, HCM Wealth Advisors requires clients to provide written authority to
determine the custodian to use. HCM Wealth Advisors allows the client to select the Custodian; however,
HCM Wealth Advisors generally recommends but does not require that clients establish brokerage
accounts with the Schwab Institutional division of Charles Schwab & Co., Inc. ("Schwab"), a FINRA
registered broker-dealer, member SIPC, to maintain custody of clients' assets and to effect trades for their
accounts. Although we recommend that clients establish accounts at Schwab, the selection of a
custodian is the client's decision. HCM Wealth Advisors is independently owned and operated and not
affiliated with Schwab.
Schwab provides HCM Wealth Advisors with access to its institutional trading and custody services,
which are typically not available to Schwab retail investors. These services generally are available to
independent investment advisers who custody assets at Schwab Institutional, on an unsolicited basis, at
no charge. Schwab's brokerage services include the execution of securities transactions, custody,
research, and access to mutual funds and other investments that are otherwise generally available only to
institutional investors or would require a significantly higher minimum investment.
For our client accounts maintained in its custody, Schwab generally does not charge separately for
custody services but is compensated by account holders through commissions and other transaction-
related fees for securities trades that are executed through Schwab or that settle into Schwab accounts.
Schwab’s commission rates applicable to our client accounts were negotiated based on the condition that
our clients collectively maintain a total of at least $10 million of their assets in accounts at Schwab. This
commitment benefits you because the overall commission rates you pay are lower than they would be
otherwise. Effective October 7, 2019, Schwab does not charge transaction fees for online stock and ETF
trades, but will still charge transaction fees on other types of security transactions. Schwab’s most recent
pricing schedules are available at schwab.com/aspricingguide.
In addition to transaction-related fees, Schwab charges you a flat dollar amount as a “prime broker” or
“trade away” fee for each trade that we have executed by a different broker-dealer but where the
securities bought or the funds from the securities sold are deposited (settled) into your Schwab account.
These fees are in addition to the transaction-related fees or other compensation you pay the executing
broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most
trades for your account. We have determined that having Schwab execute most trades is consistent with
our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a
transaction based on all relevant factors.
Schwab Institutional also makes available to us other products and services that benefit us but may not
directly benefit our clients' accounts. Many of these products and services may be used to service all or
some substantial number of our client accounts, including accounts not maintained at Schwab.
Schwab's products and services that assist us in managing and administering our clients' accounts
include software and other technology that:
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1. provide access to client account data (such as trade confirmations and account statements);
2. facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
3. provide research, pricing and other market data;
4. facilitate payment of our fees from clients' accounts; and
5. assist with back-office functions, recordkeeping and client reporting.
Schwab Institutional also offers other services intended to help manage our business. These services
may include:
1. compliance, legal and business consulting;
2. publications and conferences on practice management;
3. access to employee benefits providers, human capital consultants and insurance providers.
Schwab may make available, arrange and/or pay third-party vendors for the types of services rendered to
HCM Wealth Advisors. Schwab Institutional 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 our Firm.
Schwab Institutional may also provide other benefits such as educational events or occasional business
entertainment of our personnel. In evaluating whether to recommend that clients custody their assets at
Schwab, we may take into account the availability of some of the foregoing products and services and
other arrangements as part of the total mix of factors we consider and not solely on the nature, cost or
quality of custody and brokerage services provided by Schwab. This creates a potential conflict of
interest.
HCM Wealth Advisors will block trades where possible and when advantageous to clients. This blocking
of trades permits the trading of aggregate blocks of securities composed of assets from multiple client
accounts, so transaction costs are shared equally and on a pro-rated basis between all accounts included
in any such block.
HCM Wealth Advisors' block trading policy and procedures are as follows:
1) Transactions for any client account may not be aggregated for execution if the practice is prohibited
by or inconsistent with the client's advisory agreement with HCM Wealth Advisors, or our order
allocation policy.
2) The trading desk in concert with the portfolio manager must determine that the purchase or sale of
the particular security involved is appropriate for the client and consistent with the client's
investment objectives and with any investment guidelines or restrictions applicable to the client's
account.
3) The portfolio manager must reasonably believe that the order aggregation will benefit and will
enable HCM Wealth Advisors to seek best execution for each client participating in the aggregated
order. This requires a good faith judgment at the time the order is placed for the execution. It does
not mean that the determination made in advance of the transaction must always prove to have
been correct in the light of a "20-20 hindsight" perspective. Best execution includes the duty to seek
the best quality of execution, considering net price, as well as other factors.
4) If the order cannot be executed in full on the same day, the securities actually purchased or sold by
the close of each business day must be allocated pro rata among the participating client accounts
in accordance with the initial order ticket or other written statement of allocation. However,
adjustments to this pro rata allocation may be made to participating client accounts in accordance
with the initial order ticket or other written statement of allocation.
5) HCM Wealth Advisors’ client account records separately reflect, for each account in which the
aggregated transaction occurred, the securities which are held by, and bought and sold for that
account.
6) Funds and securities for aggregated orders are clearly identified on HCM Wealth Advisors' records
and to the broker-dealers or other intermediaries handling the transactions, by the appropriate
account numbers for each participating client.
7) No client or account will be favored over another.
Please Note: In the event that the client directs us to effect securities transactions for the client's
accounts through a specific broker-dealer, the client correspondingly acknowledges that such direction
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may cause the accounts to incur higher commissions or transaction costs than the accounts would
otherwise incur had the client determined to effect account transactions through alternative clearing
arrangements that may be available through us.
Item 13 Review of Accounts
Underlying securities within Client accounts are monitored continuously; client accounts also are
reviewed regularly. Accounts are reviewed in the context of each client's stated investment objectives
and guidelines. More frequent reviews may be triggered by material changes in variables such as the
client's individual circumstances, or the market, political or economic environment. We implement
security adjustments when deemed appropriate by our investment committee and address your
rebalancing needs at least quarterly and contact you at least annually. Tax harvesting adjustments to
your account may be made during times of market volatility.
These accounts are reviewed by the Investment Advisors and by the Investment Analysts.
In addition to the monthly statements and confirmations of transactions that clients receive from their
Custodian, we provide reports and/or electronic access to account summaries for those clients who
request these reports.
Item 14
Client Referrals and Other Compensation
HCM Wealth Advisors does not compensate for client referrals.
For accounts of HCM Wealth Advisors’ clients maintained in custody at Schwab, Schwab will not charge
the client separately for custody but will receive compensation from HCM Wealth Advisors’ clients in the
form of commissions or other transaction-related compensation on securities trades executed through
Schwab. Schwab also will receive a fee (generally lower than the applicable commission on trades it
executes) for clearance and settlement of trades executed through broker-dealers other than Schwab.
Schwab’s fees for trades executed at other broker-dealers are in addition to the other broker-dealer’s fees.
Thus, HCM Wealth Advisors may have an incentive to cause trades to be executed through Schwab rather
than another broker-dealer. HCM Wealth Advisors nevertheless, acknowledges its duty to seek best
execution of trades for client accounts. Effective October 7, 2019, Schwab does not charge transaction
fees for online stock and ETF trades, but will still charge transaction fees on other types of security
transactions. Schwab’s most recent pricing schedules are available at schwab.com/aspricingguide.
Trades for accounts custodied at Schwab may be executed at different times and different prices than
trades for accounts that are executed at other broker-dealers, if the client chooses a different broker-
dealer. It is our policy not to accept or allow our related persons to accept any form of compensation,
including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services
we provide to our clients. As part of our employee compensation package, incentive bonuses may be
allocated based on successful completion of a variety of goals including new client relationships.
Item 15 Custody
We previously disclosed in Item 5, the Fees and Compensation Section of this Brochure, that our Firm
directly debits advisory fees from client accounts.
Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients
to carefully review their custodial statements to verify the accuracy of the calculation, among other things.
Clients should contact us directly if they believe that there may be an error in their statement.
Our clients’ assets are held in custody at Charles Schwab & Company or at the custodian they choose.
For a limited number of Client’s employer sponsored 401k Accounts, Clients have granted HCM Wealth
Advisors the ability to review those accounts at the Custodian for the purpose of assisting with security
selection. We do not handle deposits, withdrawals or deduction of fees from those accounts. Our sole
responsibility is to review and select the securities and to place trades based on the Client’s Investment
Policy Statement. Because HCM Wealth Advisors has client account passwords, HCM Wealth Advisors is
required to have a surprise custody audit. Also, clients may have standing letters of authorization on their
accounts. HCM Wealth Advisors has reviewed those relationships and determined that they meet the
IAA no action letter seven conditions and do not trigger the surprise custody audit. If any standing letters
of authorization do not meet the no action letter requirements, those accounts will be included in the
surprise custody audit.
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Item 16
Investment Discretion
Clients hire us to provide discretionary asset management services, in which case we place trades in a
client's account without contacting the client prior to each trade to obtain the client's permission.
Our discretionary authority includes the ability to do the following without contacting the client:
• Determine the security to buy or sell; and/or
• Determine the amount of the security to buy or sell
Clients give us discretionary authority when they sign a Portfolio Management Agreement with our Firm.
Item 17 Voting Client Securities
In accordance with its fiduciary duty to clients and Rule 206(4)-6 of the Investment Advisers Act, HCM
Wealth Advisors has adopted and implemented written policies and procedures governing the voting of
client securities. All proxies that HCM Wealth Advisors receives will be treated in accordance with these
policies and procedures.
We vote proxies for client accounts, at the request of the client. If the client would like HCM Wealth
Advisors to take this responsibility, this preference is indicated in the Portfolio Management Agreement
and on the Custodian Application.
HCM Wealth Advisors has engaged the services of Broadridge's ProxyEdge platform to vote and maintain
records of proxies. The Broadridge open architecture platform allows HCM Wealth Advisors to choose
from several different proxy advisory firms to make recommendations on how our firm should vote the
proxies. HCM Wealth Advisors has selected "Glass Lewis" as the current advisor, who considers the
reputation, experience, and competence of a company's management and board of directors when it
evaluates an issuer.
Clients may obtain a copy of our complete proxy voting policies and procedures by telephone, email or in
writing at the contact information on the front of this document. In addition, our complete proxy voting
record is available to our clients. Clients should contact us at the phone number on the front of this
document if they have any questions or if they would like to review any of these documents.
Item 18 Financial Information
HCM Wealth Advisors has no financial circumstances to report and has never been the subject of a
bankruptcy petition at any time.
Privacy Notice To Our Clients.
We have adopted this policy with recognition that protecting the privacy and security of the personal
information we obtain about our customers is an important responsibility. We also know that the customer
expects us to service their accounts in an accurate and efficient manner. To do so, we must collect and
maintain certain personal information about our customers. We want the customer to know what
information we collect and how we use and safeguard that information.
What Information We Collect
We collect certain nonpublic personal identifying information about our customers (such as name,
address, social security number, etc.) from information that the customer provides on applications or other
forms as well as communications (electronic, telephone, written, or in person) with the customer or
authorized representatives (such as attorneys, accountants, etc.). We also collect information about
brokerage accounts and transactions (such as purchases, sales, account balances, inquiries, etc.).
What Information We Disclose
We do not disclose the nonpublic personal information we collect about our customers to anyone except:
(i) in furtherance of our business relationship and then only to those persons necessary to effect the
transactions and provide the services that the customer authorizes (such as broker-dealers, custodians,
independent managers, etc.); (ii) persons assessing our compliance with industry standards (e.g.
professional licensing authorities, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise
provided by law.
We are permitted by law to disclose the nonpublic personal information about our customers to
governmental agencies and other third parties in certain circumstances (such as third parties that perform
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administrative or marketing services on our behalf or for joint marketing programs). These third parties
are prohibited to use or share the information for any purpose. If the customer decides at some point to
either terminate our services or become an inactive customer, we will continue to adhere to our privacy
policy, as may be amended from time to time.
Security of Customer Information
We restrict access to customer nonpublic personal information to those employees who need to know
that information to service the accounts. We maintain physical, electronic, and procedural safeguards
that comply with applicable federal or state standards to protect customer personal information.
Changes To Our Privacy Policy Or Relationship With The Customer
Our policy about obtaining and disclosing information may change from time to time. We will provide the
customer notice of any material change to this policy before we implement the change.
If your personal information with us becomes inaccurate, or if you need to make a change to that
information, please contact us at the number shown below so we can update our records.
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6116 Harrison Avenue Cincinnati, Ohio 45247
Part 2B of Form ADV
Firm Brochure
February 12, 2026
Phone:
513.598.5120
Email:
info@hcmwealthadvisors.com
Website: hcmwealthadvisors.com
This brochure supplement provides information about Michael Thomas Hengehold, Casey Michael
Boland, Jake Elliott Butcher, Matthew Nicholas Calme, James Randall Eutsler, Steven Elias Hengehold,
Douglas Peter Johnson, Gregory Allen Middendorf, and Daniel Christopher Rinck. It supplements
Hengehold Capital Management LLC’s accompanying Form ADV brochure. Please contact us at
513.598.5120 or info@hcmwealthadvisors.com if you have any questions about the Form ADV brochure
or this supplement, or if you would like to request additional or updated copies of either document.
Additional information is available on the SEC’s website at www.adviserinfo.sec.gov.
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CRD Number:2377351
Items 1 and 2 Educational Background and Business Experience
Michael T. Hengehold - Year of Birth: 1956
Education: BS Degree in Accounting, Thomas More College; MS Degree in Taxation 1979, DePaul
University; Certified Public Accountant (CPA) Ohio Board of Accountancy 1980; Personal Financial
Specialist Designation CPA*PFS American Institute of CPAs 2001. 2019 RICP® Business Background:
08/79 - 11/83 Ernst & Young (formerly Ernst & Ernst, Ernst & Whinney); 11/83 - 10/90 Vice President and
Manager of Tax and Financial Planning for Hengehold Group, LLC; 10/90 to Present: Owner and Chief
Investment Officer Hengehold Capital Management LLC dba HCM Wealth Advisors. 01/19 to Present:
Majority Owner of HG CPAs LLC dba HCM CPAs.
CRD Number:2176984
Casey Boland - Year of Birth: 1969
Education: Liberal Arts Program, University of Cincinnati; Executive Certificate in Financial Planning,
Xavier University. He has passed the Series 63 (1991) and Series 65 (1996).
Business Background: 10/91 - 10/93 Paine Webber; 10/93 - 10/94 Fidelity Investments; 10/94 - 9/96 The
Forethought Group; 9/96 - 6/97 Paine Webber; 7/97 - 2/98 G & K Services; 3/98 - 7/99 Nations Banc
Investments, Inc.; 8/99 - 8/00 Gradison McDonald Investments; 8/00 - Present Hengehold Capital
Management LLC dba HCM Wealth Advisors.
CRD Number:5058104
Jake Butcher – Year of Birth: 1988
Education: BBA Degree in Finance, University of Cincinnati 2011; Executive Certificate in Financial
Planning, Xavier University; CERTIFIED FINANCIAL PLANNER® (CFP®) Certified Financial Planner
Board of Standards 2014.
Business Background: 2005-2007 Wagoner, Wagoner & Associates; 2008 Ultimus Fund Solutions; 2010
– Present Hengehold Capital Management LLC dba HCM Wealth Advisors.
CRD Number: 6353065
Matt Calme - Year of Birth: 1991
Education: BA Degree in Finance, Northern Kentucky University, Highland Heights, KY, 2014. He has
passed the Securities Industry Essentials Examination (SIE, 10/2018), Series 7 (07/2014), Series 66
(03/2017) and Series 63 (07/2014). CERTIFIED FINANCIAL PLANNER® (CFP®) July 2017.
Business Background: 06/2014-04/2019 Fidelity Brokerage Services LLC; 07/2018 – 04/2019 Fidelity
Personal and Workplace Advisors, 04/2019 – Present Hengehold Capital Management LLC dba HCM
Wealth Advisors.
CRD Number:6545987
James Eutsler - Year of Birth: 1976
Education: BS Degree in Chemistry – Wright State University (1999); Master’s in Business Administration
(MBA) - Xavier University (2003); Certified Management Accountant (2008) – Institute of Management
Accountants; Executive Certificate in Financial Planning – Xavier University (2015); Series 65 (2015). He
has earned the Certified Management Accountant as of March 2007, the Chartered Financial Consultant
(ChFC®) as of March 2017, the CERTIFIED FINANCIAL PLANNER® (CFP®) July 2017, and an Enrolled
Agent (EA) 2023.
Business Background: British Petroleum,1996 - 1999; Procter & Gamble, 1999 - 2015; 2015 – Present
Hengehold Capital Management LLC dba HCM Wealth Advisors
CRD Number:6561418
Steven Hengehold – Year of Birth: 1990
Education: BA Finance and Economics from The University of South Carolina 2012; Graduate Certificate
in Financial Planning from Kansas State University 2014; Series 65 (2015); CERTIFIED FINANCIAL
PLANNER® (CFP®) Certified Financial Planner Board of Standards 2016. RICP® 2019
Business Background: 2011-2012 Abacus Planning Group, 2012-2013 Insight Global, 2013-2014
Colonial Life; 2014 – Present Hengehold Capital Management LLC dba HCM Wealth Advisors.
CRD Number:4730228
Doug P. Johnson – Year of Birth: 1980
Education: BA Economics from Centre College, Danville, KY 2002; Chartered Financial Analyst (CFA),
2008
Business Background: 2006-2017, Ameriprise Financial Services, Inc.; 2017 – Present, Hengehold
Capital Management LLC. 2020 – Present, Chief Compliance Officer, Hengehold Capital Management
LLC dba HCM Wealth Advisors.
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CRD Number:6429344
Greg Middendorf - Year of Birth: 1981
Education: BA Degree in Finance Xavier University 2003; CERTIFIED FINANCIAL PLANNER® (CFP®)
Certified Financial Planner Board of Standards 2009. Certified College Planning Specialist (CCPS®) 2015
Business Background: 1999 - 2003 American Money Management; 2003 - 2009 Johnson Investment
Counsel; 2009 - Present Hengehold Capital Management LLC dba HCM Wealth Advisors.
CRD Number:6069553
Daniel Rinck - Year of Birth: 1989
Education: BSBA Degree in Accounting, Xavier University 2011. He has passed the Series 65 (05/2021).
Business Background: 04/2014 - 10/2017, Associate Financial Advisor, Northwestern Mutual; 10/2017 –
Present, Associate Wealth Advisor, Hengehold Capital Management LLC dba HCM Wealth Advisors.
Item 3 Disciplinary Information
There have been no disciplinary actions taken against anyone on our staff.
Item 4 Other Business Activities
Michael Hengehold is the majority owner of HG CPAs LLC (HG) dba HCM CPAs, working as a tax
accountant to provide various tax services to clients. Specifically, to the extent that HG provides accounting
and/or tax preparation services to any clients, including clients of HCM Wealth Advisors, all such services
shall be performed by HG, in its individual professional capacity, independent of HCM Wealth Advisors, for
which services HCM Wealth Advisors shall not receive any portion of the fees charged by HG, referral or
otherwise. The members of HG, solely incidental to their respective practices as Certified Public
Accountants with HG may recommend HCM Wealth Advisors’ services to certain clients of HG. No client
of HCM Wealth Advisors is under any obligation to use the services of HG. HCM Wealth Advisors’ clients
may receive a discount on HG’s services. HCM Wealth Advisors’ Principal, Michael Hengehold, remains
available to address any questions that a client or prospective client may have regarding the above
arrangement and any corresponding perceived conflict of interest such arrangement may create. HCM
Wealth Advisors also attempts to mitigate the conflict of interest by requiring employees to acknowledge in
the firm’s Code of Ethics, their individual fiduciary duty to the clients of HCM Wealth Advisors, which
requires that employees put the interests of clients ahead of their own.
Our advisors are not involved in any other investment related business activity.
Item 5 Additional Compensation
Our advisors do not receive compensation from any other business outside our Firm. As part of our
employee compensation package, incentive bonuses may be allocated based on successful completion
of a variety of goals including new client relationships.
Item 6 Supervision
Michael T. Hengehold, is the Majority Owner and supervises the advisory activities for the Firm. He can
be contacted at 513.598.5120. Doug Johnson, Chief Compliance Officer, is responsible for monitoring the
activities of HCM Wealth Advisor’s supervised persons. Mr. Johnson’s telephone number is 513-598-
5120. Mr. Johnson conducts client contact and continuously reviews investment strategies and market
conditions. Mr. Johnson has an Investment Adviser Supervisory Manual and Code of Ethics that are
annually reviewed.
Explanation of Minimum Requirements for Various Credentials
Chartered Financial Analyst (CFA) – The Chartered Financial Analyst (CFA) charter is a globally
respected, graduate-level investment credential established in 1962 and awarded by CFA Institute — the
largest global association of investment professionals. There are currently more than 90,000 CFA
charterholders working in 135 countries. To earn the CFA charter, candidates must: 1) pass three
sequential, six-hour examinations; 2) have at least four years of qualified professional investment
experience; 3) join CFA Institute as members; and 4) commit to abide by, and annually reaffirm, their
adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct.
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High Ethical Standards The CFA Institute Code of Ethics and Standards of Professional Conduct,
enforced through an active professional conduct program, require CFA charterholders to:
• Place their clients’ interests ahead of their own
• Maintain independence and objectivity
• Act with integrity
• Maintain and improve their professional competence
• Disclose conflicts of interest and legal matters
Global Recognition
Passing the three CFA exams is a difficult feat that requires extensive study (successful candidates report
spending an average of 300 hours of study per level). Earning the CFA charter demonstrates mastery of
many of the advanced skills needed for investment analysis and decision making in today’s quickly
evolving global financial industry. As a result, employers and clients are increasingly seeking CFA
charterholders—often making the charter a prerequisite for employment. Additionally, regulatory bodies
in 19 countries recognize the CFA charter as a proxy for meeting certain licensing requirements, and
more than 125 colleges and universities around the world have incorporated a majority of the CFA
Program curriculum into their own finance courses.
Comprehensive and Current Knowledge
The CFA Program curriculum provides a comprehensive framework of knowledge for investment decision
making and is firmly grounded in the knowledge and skills used every day in the investment profession.
The three levels of the CFA Program test a proficiency with a wide range of fundamental and advanced
investment topics, including ethical and professional standards, fixed-income and equity analysis,
alternative and derivative investments, economics, financial reporting standards, portfolio management,
and wealth planning.
The CFA Program curriculum is updated every year by experts from around the world to ensure that
candidates learn the most relevant and practical new tools, ideas, and investment and wealth
management skills to reflect the dynamic and complex nature of the profession. To learn more about the
CFA charter, visit www.cfainstitute.org.
CERTIFIED FINANCIAL PLANNER® (CFP® ) In order to achieve and maintain certification,
CFP® professionals must: 1) pass the comprehensive CFP® Certification Examination, 2) pass the CFP
Board's Fitness Standards for Candidates and Registrants, 3) agree to abide by CFP Board's Code of
Ethics and Professional Responsibility and Rules of Conduct which put clients' interests first, 4) comply
with the Financial Planning Practice Standards which spell out what clients should be able to reasonably
expect from the financial planning engagement, and 5) complete 30 hours of continuing education
(including 2 hours of approved Ethics CE) every two years. - See more at: http://www.cfp.net/become-a-
cfp-professional/cfp-certification-requirements#sthash.qwXJz3yF.dpuf.
Certified Public Accountant (CPA) – CPAs are licensed and regulated by their state boards of
accountancy. While state laws and regulations vary, the education, experience and testing requirements
for licensure as a CPA generally include minimum college education (typically 150 credit hours with at
least a baccalaureate degree and a concentration in accounting), minimum experience levels (most
states require at least one year of experience providing services that involve the use of accounting, attest,
compilation, management advisory, financial advisory, tax or consulting skills, all of which must be
achieved under the supervision of or verification by a CPA), and successful passage of the Uniform CPA
Examination.
In order to maintain a CPA license, states generally require the completion of 40 hours of continuing
professional education (CPE) each year (or 80 hours over a two year period or 120 hours over a three
year period). Additionally, all American Institute of Certified Public Accountants (AICPA) members are
required to follow a rigorous Code of Professional Conduct which requires that they act with integrity,
objectivity, due care, competence, fully disclose any conflicts of interest (and obtain client consent if a
conflict exists), maintain client confidentiality, disclose to the client any commission or referral fees, and
serve the public interest when providing financial services.
Personal Financial Specialist (PFS) – The PFS credential demonstrates that an individual has met the
minimum education, experience and testing required of a CPA in addition to a minimum level of expertise
in personal financial planning. To attain the PFS credential, a candidate must hold an unrevoked CPA
license, fulfill 3,000 hours of personal financial planning business experience, complete 80 hours of
personal financial planning CPE credits, pass a comprehensive financial planning exam and be an active
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member of the AICPA. A PFS credential holder is required to adhere to AICPA’s Code of Professional
Conduct and is encouraged to follow AICPA’s Statement on Responsibilities in Financial Planning
Practice.
To maintain their PFS credential, the recipient must complete 60 hours of financial planning CPE credits
every three years. The PFS credential is administered through the AICPA.
Certified College Planning Specialist (CCPS®)
Three module examinations administered by the National Institute of Certified College Planners (NICCP).
Chartered Financial Consultant (ChFC®) is the financial planning designation for the insurance industry
awarded by the American College of Bryn Mawr. ChFCs must meet experience requirements and pass
exams covering finance and investing. They must have at least three years of experience in the financial
industry, and have studied and passed an examination on the fundamentals of financial planning,
including income tax, insurance, investment and estate planning. The ChFC designation must be
renewed every two years and complete a minimum of 30 hours of continuing education. For more
information on the ChFC designation and a ChFC informational brochure, go to
www.ChFCHighestStandard.com or www.TheAmericanCollege.edu/chfc.
Certified Management Accountant (CMA) is a certification for accounting professionals who have
demonstrated ability in strategic management and financial accounting. The CMA certification is
voluntary, issued by the Institute of Management Accountants, and each CMA is subject to a code of
ethics. CMAs are required to have a bachelor’s degree and have no less than two years of work
experience, of which two years must be in management accounting.
Retirement Income Certified Professional (RICP®) A retirement income certified professional (RICP)
specializes in retirement income planning. The RICP is a designation given to professionals who have
completed the RICP training program. RICPs must meet experience requirements and pass courses
covering retirement income an strategies. They must have at least three years of experience in the
financial industry, and have studied and passed an examination on the fundamentals of financial
planning, including income tax, insurance, investment and estate planning. For more information on the
RICP designation, go to https://www.theamericancollege.edu/designations-degrees/RICP
The EA designation (EA) is issued by the Internal Revenue Service. Candidates must pass a
background check to ensure that they have not engaged in any conduct that would justify suspension
from practice before the IRS. Candidates may pass a written exam or have accepted IRS experience.
Candidates must complete 72 hours of continuing education credits over a three-year enrollment period,
with a minimum of 16 hours each year. Six hours of ethics training is required over a three-year
enrollment period.
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