HERITAGE FAMILY OFFICES, LLP

Item 1 – Cover Page Part 2A of Form ADV 9841 E Bell Rd, Ste 110 Scottsdale, AZ 85260 Telephone: (602) 775-5400 Fax: (602) 775-5451 Email: mfrost@heritagefo.com Web Address: www.heritagefo.com June 2025 This Brochure provides information about the qualifications and business practices of Heritage Family Offices, LLP. If you have any questions about the contents of this Brochure, please contact us using the information listed above. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Heritage Family Offices, LLP (CRD# 323930) is a registered investment advisor with the SEC. Registration of an investment advisor does not imply any certain level of skill or training. Additional information about Heritage Family Offices, LLP, is also available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2 – Material Changes Since the last filing of this brochure, the following has changed: • Change in CCO from David Maxey to Michael Frost 2  Item 3 – Table of Contents Item 1 – Cover Page ...............................................................................................................1 Item 2 – Material Changes ......................................................................................................2 Item 3 – Table of Contents .....................................................................................................3 Item 4 – Advisory Business .....................................................................................................4 Item 5 – Fees and Compensation ............................................................................................6 Item 6 - Performance-Based Fees and Side-By-Side Management ............................................8 Item 7 – Types of Clients & Account Minimums ......................................................................8 Item 8 – Methods of Analysis, Investment Strategies, Investment Tools, and Risk of Loss ........9 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 Trading12 Item 12 – Brokerage Practices .............................................................................................. 13 Item 13 – Review of Accounts ............................................................................................... 14 Item 14 – Client Referrals and Other Compensation .............................................................. 15 Item 15 – Custody ................................................................................................................ 15 Item 16 – Investment Discretion ........................................................................................... 16 Item 17 – Voting Client Securities ......................................................................................... 16 Item 18 – Financial Information ............................................................................................ 16 3  Item 4 – Advisory Business Description of the Advisory Firm A. Heritage Family Offices, LLP (“HFO”), was formed in July 2018 and based in Phoenix, Arizona. HFO and has been providing investment advisory services since November 2011 (under a prior name). HFO’s principal owners are Michael Frost, Ralph Nelson III and David Maxey. Michael Frost is the Chief Compliance Officer (CCO). HFO is a member of a family of companies that are separately owned by a common group of individuals. B. Types of Advisory Services WEALTH MANAGEMENT s HFO offers wealth management services to advisory Clients. HFO will offer Clients ongoing wealth management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. HFO manages assets on a discretionary basis, meaning the Client will sign a limited trading authorization or equivalent allowing HFO to determine the securities to be bought or sold and the amount of the securities to be bought or sold. HFO will have the authority to execute transactions in the account without seeking Client approval for each transaction. HFO may also select and appoint one or more Sub-Advisor(s) to provide Sub-Advisor Services to Client’s Account. Such Sub-Advisor Services will be as determined by HFO. Such Sub-Advisor(s), in providing Sub-Advisor Services, shall have all the same authority relating to the management, including fee deduction authority, of Client’s Account as is granted to HFO. In addition, at HFO’s discretion, HFO may grant such Sub-Advisor(s) full authority to further delegate such discretionary investment authority to other Money Managers. Client will agree to such authority within HFO’s Advisory Agreement. All fees paid by Client to HFO are exclusive, and in addition to the fees paid to Sub-Advisor. HFO may also recommend that certain qualified Clients consider an investment in private funds/offerings. HFO’s role relative to the private investment funds can include, but not limited to, initial and ongoing due diligence, fund management, and investment monitoring services. HFO’s Clients are under no obligation to consider or make an investment in private investment funds. Each prospective private fund investor will be required to complete a Subscription Agreement or similar application, pursuant to which the Client shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Please see Item 8 for more information on the risks associated with this type of investment. FAMILY OFFICE SERVICES HFO provides Clients with information, advice and recommendations about matters including asset allocation; portfolio construction; financial planning - including family governance and succession planning; investment manager selection; estate planning; tax planning, tax return 4  preparation and bookkeeping, and insurance. Each of our Clients is served by a team led by a designated Advisor and is supported by our in-house investment team and subject matter experts. • Clearly communicated, actionable, and concise information, advice, and recommendations; • Subject-matter expertise and support across wealth management disciplines; • Access to high-quality investments and financial services; • Coordination of Clients’ “ecosystems” of professional and financial service providers to ensure the Client’s advisors are focused on their goals; and • Administrative capabilities to organize and manage the detail and complexity of our Clients’ wealth Family Office Services involves developing a comprehensive financial plan covering specific or multiple topics such as Estate and Legal Planning, Investment Planning, Retirement Planning, Insurance Planning, Tax Planning, Education Planning, Portfolios Review, Asset Allocation, and Real Estate Planning. When providing financial planning services, the role of HFO is to find ways to help our Clients understand their overall financial situation and help them set financial objectives. Our Family Office Services do not involve implementing any transaction on the Client’s behalf or the active and ongoing monitoring or management of their investments or accounts. The Client has the sole responsibility for determining whether to implement our financial planning recommendations. To the extent that the Client would like to implement any of our investment recommendations through HFO or retain HFO to actively monitor and manage their investments, they must execute a separate written agreement with HFO for our wealth management services. Results of the periodic financial plan review will be communicated to Client via in person meeting, telephone consultation, or written report. Client recognizes that HFO’s Family Office Services are dependent upon Client timely providing HFO with current information pertaining to Client’s financial situation, investment objectives and risk tolerance. Client will timely notify HFO of any changes to Client’s financial situation or investment objectives. Upon beginning a periodic financial plan review, HFO will contact Client to determine whether Client’s financial situation, investment objectives or risk tolerance have changed, or if Client has any specific areas of concern relating to Client’s financial plan. Client understands that ongoing Family Office Services do not include wealth management services, implementation of HFO’s recommendations, or any other similar services. For accounts not held by a custodian such as fixed annuities, 401ks, and other similar products, the advisor may recommend allocations and/or provide consolidated reporting. If subject to the Wealth Management Services engagement and fee, these outside accounts must be specified in the Client’s agreement with HFO. If a conflict of interest exists between the interests of HFO and the interests of the Client, the Client is under no obligation to act upon HFO’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to affect the transaction through HFO. C. Client-Tailored Services and Client-Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on 5  investing in certain securities or types of securities. These restrictions may, however, prohibit engagement with HFO. D. Wrap Fee Programs HFO does not participate in a Wrap Program. E. Amounts Under Management As of December 31, 2024, HFO provides management services for: Discretionary Assets: $408,105,385 Non-Discretionary Assets: $0 Item 5 – Fees and Compensation A. Fee Schedule WEALTH MANAGEMENT HFO offers wealth management services to advisory Clients. HFO charges an annual investment advisory fee based on the total assets under management as follows: Assets Under Management Maximum Annual Fee All Assets 2.00% Fees are billed monthly in arrears based on the amount of assets managed as of the close of business on the last business day of the previous billing period. If margin is utilized, the fees will be billed based on the net asset value of the account. Lastly, please note that HFO may group certain related Client accounts, often known as “householding”, for the purposes of achieving the minimum account size and determining the annualized fee. If a portion of the Client’s assets are managed by Sub-Advisor(s), Sub-Advisor(s) will charge a management fee, generally ranging from 0.25% to 0.50%, in addition to and separate from HFO’s advisory fees. The Sub-Adviser will deduct their fee directly from the Client’s account. Sub-Advisors bill their fees quarterly in advance. Additional fees will be paid by the Client for any services provided by HFO’s affiliated entities. Such fees will be subject to a separate engagement contract. No fees will be incurred by the Client prior to signing the separate engagement contract. FAMILY OFFICE SERVICES HFO charges a fixed or ongoing fee for Family Officer Services. Prior to the process the Client will be provided an estimated plan fee, which may include a one-time initial onboarding fee, which will 6  be based on the complexity of the engagement. HFO reserves the right to waive the fee should the Client implement the plan through HFO by executing a Wealth Management Services Agreement. FIXED FEES Fixed Fee Services are offered based on a fixed fee to never exceed $250,000 depending on the complexity of the engagement. Fees are billed upon completion of the service. ONGOING FEES Ongoing Fee Services are offered based on an annual fee to never exceed $250,000, charged monthly depending on the Client’s election. Fees are billed in arrears of each billing period. Ongoing Fee Services will continue year after year until canceled, in writing, by either HFO or the Client. Clients that engage HFO for Family Office Services will pay one fee for services rendered through HFO by our affiliates. The total fee will range based on the services provided by our affiliates and will be payable monthly in arrears. Clients will be provided with an invoice outlining the service provider and fee due for services rendered. Lastly, HFO reserves the right to increase the fee by 3% each year. This fee increase will be noted on the executed Client agreement. B. Payment of Fees Wealth Management Fees are deducted directly from the Client’s Account. Sub-Advisor Fees are deducted directly from the Client’s Account. Family Office Services Fees are generally invoiced directly to the Client but may also be deducted from another account held with HFO. HFO, in its sole discretion, may charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). For all services, Clients may terminate their engagement with HFO within five (5) business days of signing an Agreement with no obligation and without penalty. After the initial (5) business days, the Agreement may be terminated by HFO with thirty (30) days written notice to Client and by the Client at any time with written notice to HFO. For accounts opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. All unpaid earned fees will be due to HFO, and all unearned fees will be refunded to the Client. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. C. Additional Fees Custodians may charge brokerage commissions, transaction fees, and other related costs on the purchases or sales of mutual funds, equities, bonds, options, margin interest, and exchange-traded funds. Mutual funds, money market funds, and exchange-traded funds may also charge internal management fees, which are disclosed in the fund’s prospectus. HFO does not directly receive any 7  compensation from these fees. All of these fees are in addition to the management fee you pay to HFO. For more details on the brokerage practices, see Item 12 of this brochure. D. Prepayment of Fees Sub-Advisors bill their fees quarterly in advance. Ongoing Family Office Services fees are billed monthly in arrears. E. External Compensation for the Sale of Securities HFO and/or its Investment Advisor Representatives may receive external compensation from affiliations as a general or limited partner of private funds/offerings or other pooled investment vehicles. HFO may recommend these funds as investments for certain qualifying clients. This represents a conflict of interest because it gives an incentive to recommend investment in these funds as the general partners will receive additional fees. This conflict is mitigated by disclosures, procedures and HFO’s fiduciary obligation to place the best interest of the Client first. Moreover, Clients are under no obligation to invest in such partnerships. Item 6 - Performance-Based Fees and Side-By-Side Management As the general partner (or similar function) to affiliated private funds/offerings, HFO may receive performance-based compensation from the funds. Such performance-based compensation is generally calculated based on a share of all net realized income and gains and losses of the funds. Investors and prospective investors in any of the funds should note that performance-based compensation, in some contexts, can create an incentive for HFO to recommend investments which may be riskier or more speculative than those which would be recommended under a different fee arrangement. Side-by-side management refers to multiple client relationships where an adviser manages more than one client relationship or portfolio on a simultaneous basis. Various conflicts of interest arise by such side-by-side management. For example, in theory, HFO could have incentive to favor a fund paying performance-based compensation over one that does not pay performance-based compensation. Or a fund paying higher aggregate performance-based compensation over one paying less. This conflict is mitigated by disclosures, procedures and HFO’s fiduciary obligation to place the best interest of the Client first. Item 7 – Types of Clients & Account Minimums HFO’s Clients are generally individuals, small businesses, trusts, estates, high net-worth individuals, pooled investment vehicles, and charities. Client relationships vary in scope and length of service. There is no minimum account size and Clients are not required to have a certain amount of investment experience or sophistication. 8  Item 8 – Methods of Analysis, Investment Strategies, Investment Tools, and Risk of Loss A. Methods of Analysis and Investment Strategies Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Security analysis methods may include: Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are twofold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. In developing a financial plan for a Client, HFO’s analysis may include cash flow analysis, investment planning, risk management, tax planning and estate planning. Based on the information gathered, a detailed strategy is tailored to the Client’s specific situation. The main sources of information include financial newspapers and magazines, annual reports, prospectuses, and filings with the SEC. B. Investment Strategy The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations and/or as outlined on their Statement of Investment Selection or similar document. The Client may change these objectives at any time by providing written notice to HFO. C. Risks of Investments and Strategies Utilized Investing in securities involves risk of loss that Clients should be prepared to bear. HFO’s investment approach constantly keeps the risk of loss in mind. Investors may face the following investment risks: General Investment and Trading Risks. Clients may invest in securities and other financial instruments using strategies and investment techniques with significant risk characteristics. The investment program utilizes such investment techniques as option transactions, margin transactions, short sales, leverage, and derivatives trading, the use of which can, in certain circumstances, maximize the adverse impact to which a Client may be subject. 9  Interest-rate Risk. Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Inflation Risk. When any type of inflation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of inflation. Currency Risk. Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Reinvestment Risk. This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Management Risk. The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the Client’s portfolio may suffer. Cybersecurity Risk. HFO and its service providers may be subject to operational and information security risks resulting from cyberattacks. Cyberattacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, the unauthorized release of confidential information or various other forms of cybersecurity breaches. Cybersecurity attacks affecting HFO, and its service providers may adversely impact Clients. For instance, cyberattacks may interfere with the processing of transactions, cause the release of private information about Clients, impede trading, subject HFO to regulatory fines or financial losses, and cause reputational damage. Similar types of cybersecurity risks are also present for issuers of securities in which Clients may invest in, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damages, and loss from damage or interruption of systems. Although HFO has established its systems to reduce the risk of these incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that HFO does not directly control the cybersecurity measures and policies employed by third party service providers. Options Trading. The risks involved with trading options are that they are very time-sensitive investments. An options contract is generally a few months. The buyer of an option could lose his or her entire investment even with a correct prediction about the direction and magnitude of a particular price change if the price change does not occur in the relevant time period (i.e., before the option expires). Additionally, options are less tangible than some other investments. An option is a “book-entry” only investment without a paper certificate of ownership. Trading on Margin. In a cash account, the risk is limited to the amount of money that has been invested. In a margin account, risk includes the amount of money invested plus the amount that has been loaned. As market conditions fluctuate, the value of marginable securities will also 10  fluctuate, causing a change in the overall account balance and debt ratio. As a result, if the value of the securities held in a margin account depreciates, the Client will be required to deposit additional cash or make full payment of the margin loan to bring the account back up to maintenance levels. Clients who cannot comply with such a margin call may be sold out or bought in by the brokerage firm. Capitalization Risks. Investing in Companies within the same market capitalization category carries the risk that the category may be out of favor due to current market conditions or investor sentiment. Alternative Investments. When appropriate for a Client’s objective, risk tolerance and qualifications, HFO recommends the Client participate in private issues, such as single purpose vehicles, funds of funds, private equity, and hedge funds. These are usually structured as limited partnerships with differing minimum investments, liquidity, fees and carriers. The foregoing list of risk factors does not purport to be a complete enumeration or explanation of the risks involved in an investment with HFO. Item 9 – Disciplinary Information HFO and its management have not been involved in any criminal or civil actions, administrative or self-regulatory enforcement proceedings, nor any legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of HFO or the integrity of its management. Item 10 – Other Financial Industry Activities and Affiliations A. Registration as a Broker-Dealer or Broker-Dealer Representative Neither HFO nor its management persons are registered as a broker-dealer or broker-dealer representative. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither HFO nor its management persons are registered as futures commission merchants, commodity pool operator, or a commodity trading advisor. C. Relationships Material to this Advisory Business and Possible Conflicts of Interest The other affiliated, legal entities include the following: • Heritage Insurance Advisors, LLC • Frost and Associates, LLC • HFO Payroll, LLC • HFO Management, Inc. • HFO Private Markets, LLC 11  These represent a conflict of interest because it gives an incentive to recommend services based on the fee amount received. This conflict is mitigated by disclosures, procedures and HFO’s fiduciary obligation to place the best interest of the Client first. Moreover, Clients are not required to engage the Agent or Agency if they do not wish to. More information on this can be found in the respective Investment Advisor Representative’s Form U4 and ADV 2B. HFO and/or its Investment Advisor Representatives may receive external compensation from affiliations as the general or limited partner of private funds/offerings or other pooled investment vehicles. HFO may recommend these funds as investments for certain qualifying clients. This represents a conflict of interest because it gives an incentive to recommend investment in these funds as the general partners will receive additional fees. This conflict is mitigated by disclosures, procedures and HFO’s fiduciary obligation to place the best interest of the Client first. Moreover, Clients are under no obligation to invest in such partnerships. D. Selection of Other Advisors or Managers HFO may select and appoint one or more Sub-Advisor(s) to provide Sub-Advisor Services to Client Accounts. When selecting Sub-Advisors, the Client’s best interest will be the main determining factor of HFO. HFO ensures that before selecting other Sub-Advisors that they are properly licensed or registered as an investment advisor. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics The affiliated persons (affiliated persons include employees and/or independent contractors) of HFO have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of HFO affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of HFO. The Code reflects HFO and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. HFO’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other affiliated person, officer or director of HFO may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. HFO’s Code is based on the guiding principle that the interests of the Client are our top priority. HFO’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. 12  The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. HFO will provide a copy of the Code of Ethics to any Client or prospective Client upon request. B. Recommendations Involving Material Financial Interests HFO anticipates, in appropriate circumstances and consistent with Client’s investment objectives, HFO may recommend the purchase of partnership interests in which our affiliates, directly or indirectly, have a material financial interest. HFO’s employees, directors, and partners often invest in these same partnerships. Because of the nature of these partnerships, investment by employees, partners, and directors does not influence pricing. Should a conflict arise, it will be mitigated by disclosures, procedures and HFO’s fiduciary obligation to place the best interest of the Client first. Moreover, Clients are under no obligation to invest in such partnerships. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of C. Interest HFO and its affiliated persons may invest in the same securities (or related securities, e.g., warrants, options or futures) that HFO or an affiliated person recommends to Clients. In order to mitigate conflicts of interest, such as frontrunning, HFO’s Chief Compliance Officer, or their designee, will no less than quarterly, review firm and/or personal holdings of its affiliated persons. These reviews ensure that the personal trading of affiliated persons does not disadvantage Clients of HFO. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities D. Transactions and Conflicts of Interest HFO and its affiliated persons may recommend securities, or buy or sell securities for Clients accounts, at or about the same time, that they also buy or sell the same securities in their own account(s). HFO, for instance, will place trades in an account in an attempt to earn better than money market rates. In order to mitigate conflicts of interest, such as frontrunning, HFO’s Chief Compliance Officer, or their designee, will no less than quarterly, review firm and/or personal holdings of its affiliated persons. These reviews ensure that the personal trading of affiliated persons does not disadvantage Clients of HFO. Item 12 – Brokerage Practices A. Factors Used to Select or Recommending Broker-Dealers HFO may require the use of a specific broker-dealer. HFO will select appropriate brokers based on a number of factors including but not limited to their transaction fees, quality of customer service, and reporting ability. HFO relies on the broker-dealer to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients 13  pay for any and all custodial fees in addition to the advisory fee charged by HFO. Please note that not all Investment Advisors require that their Clients direct brokerage. 1. Research and Other Soft Dollar Benefits HFO may receive soft dollar benefits from broker dealers such as research (or other products or services). Since HFO generally does not have to pay for these products or services, HFO has an incentive to select or recommend a broker-dealer based on HFO’s interest in receiving the research or other products or services, rather than the Clients’ interest in receiving the most favorable execution. HFO uses these benefits to services all Clients accounts. This conflict is mitigated by disclosures, procedures and HFO’s fiduciary obligation to place the best interest of the Client first. 2. Brokerage for Client Referrals HFO does not receive Client referrals from any custodian or third party in exchange for using that broker-dealer or third party. 3. Directed Brokerage HFO does not allow Client directed brokerage. Investment advisors who manage or supervise Client portfolios have a fiduciary obligation of best execution. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is affected, the ability to affect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. The firm does not receive any portion of the trading fees. B. Aggregating Trading for Multiple Client Accounts When a Client authorizes discretionary management, HFO is authorized in its discretion to aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of HFO. All Clients participating in the aggregated order shall receive an average share price with all other transactions. If aggregation is not allowed or infeasible and individual transactions occur (e.g., withdrawal or liquidation requests, odd-late trades, etc.) an account may potentially be assessed higher costs or less favorable prices than those where aggregation has occurred. HFO will always attempt to aggregate orders whenever it has the opportunity to do so. Item 13 – Review of Accounts A. Frequency and Nature of Periodic Review and Who Makes Those Reviews 14  Account reviews are performed at least annually by the Chief Compliance Officer of HFO. Account reviews are performed more frequently when market conditions dictate. Reviews of Client accounts include, but are not limited to, a review of Client documented risk tolerance, adherence to account objectives, investment time horizon, and suitability criteria, reviewing target allocations of each asset class to identify if there is an opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, and changes in a Client's own situation. C. Content and Frequency of Regular Reports Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by the Client’s custodian. Client receives confirmations of each transaction in account from Custodian and an additional statement during any month in which a transaction occurs. HFO may also send periodic or other event-inspired reports based on market or portfolio activity. Reports will generally be provided in electronic format. Item 14 – Client Referrals and Other Compensation A. Economic Benefits from Others Clients may be referred to invest in certain private offering to which HFO solicits on behalf of, and receives a fee. When referring Clients to a third party, the Client’s best interest will be the main determining factor of HFO. All private offerings that HFO recommends must be a Registered Investment Advisors with the SEC or with the appropriate state authority(ies). B. Compensation to Non-Advisory Personnel for Client Referrals HFO may enter into agreements with individuals and organizations, which may be affiliated or unaffiliated with HFO, that refer Clients to HFO in exchange for compensation. All such agreements will be in writing and comply with the requirements of Federal or State regulation. If a Client is introduced to HFO by a solicitor, HFO may pay that solicitor a fee. While the specific terms of each agreement may differ, generally, the compensation will be a flat fee per referral, or a percentage of the fee charged by HFO for any introduced capital. Any such fee shall be paid solely from HFO’s investment management fee and shall not result in any additional charge to the Client. Each prospective Client who is referred to HFO under such an arrangement will receive a separate written disclosure document disclosing the nature of the relationship between the solicitor and HFO. Item 15 – Custody All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at least quarterly. Clients are urged to compare the account 15  statements received directly from their custodians to any documentation or reports prepared by HFO. HFO is deemed to have limited custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of HFO. HFO will obtain written authorization from Client to allow for such deductions. HFO also has custody of funds and/or securities in certain Client accounts due to trustee appointment. These accounts are examined on a surprise basis at least annually by an outside public accounting firm unless otherwise exempted. HFO has custody over assets invested in HFO’s affiliated private funds/offerings (see Item 10 above). The private offerings are audited annually by a Public Company Accounting Oversight Board (“PCAOB”) registered and inspected accounting firm. The audit reports are distributed to investors of these offerings upon completion. HFO is not affiliated with the custodian. The custodian does not supervise HFO, its employees or activities. Item 16 – Investment Discretion If applicable, Client will authorize HFO discretionary authority, via the Advisory Agreement, to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. If applicable, Client will authorize HFO discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. If however, consent for discretion is not given, HFO will obtain prior Client approval before executing each transaction. HFO allows Clients to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. Such restrictions could include only allowing purchases of socially conscious investments. These restrictions must be provided to HFO in writing. The Client approves the custodian to be used and the commission rates paid to the custodian. HFO does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17 – Voting Client Securities When assistance on voting proxies is requested, HFO will provide recommendations to the Client. However, HFO will not have authority to vote proxies on behalf of the Client. If in the future HFO obtains authority to vote proxies, this Brochure will be appropriately amended. Item 18 – Financial Information HFO has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients and has not been the subject of a bankruptcy petition. 16  Balance Sheet A. HFO does not require nor solicit prepayment of more than $1,200 in fees per Client, six months or more in advance. Financial Condition B. At this time, neither HFO nor its management persons have any financial conditions that are likely to reasonably impair its ability to meet contractual commitments to Clients. Bankruptcy Petitions in Previous Years C. HFO has not been the subject of a bankruptcy petition in the last ten years. 17