Overview

Assets Under Management: $179 million
Headquarters: BEDMINSTER, NJ
High-Net-Worth Clients: 69
Average Client Assets: $3 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (FORM ADV PART 2A - FIRM BROCHURE)

MinMaxMarginal Fee Rate
$0 and above 2.00%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $20,000 2.00%
$5 million $100,000 2.00%
$10 million $200,000 2.00%
$50 million $1,000,000 2.00%
$100 million $2,000,000 2.00%

Clients

Number of High-Net-Worth Clients: 69
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 88.09
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 387
Non-Discretionary Accounts: 387

Regulatory Filings

CRD Number: 288232
Last Filing Date: 2024-04-03 00:00:00
Website: https://heritagenj.com

Form ADV Documents

Primary Brochure: FORM ADV PART 2A - FIRM BROCHURE (2025-09-04)

View Document Text
Item 1: Cover Page Part 2A of Form ADV: Firm Brochure September 4, 2025 442 Main Street (Route 202) Bedminster, NJ 07921 www.HeritageFinancialCounselors.com Firm Contact: Charles P. Weidman, CFP®, MBA Managing Partner firm is also available on This brochure provides information about the qualifications and business practices of Heritage Financial Counselors, LLC. If clients have any questions about the contents of this brochure, please contact us at 862-579-2899. 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. the SEC’s website at information about our Additional www.adviserinfo.sec.gov by searching CRD # 288232. Please note that the use of the term “registered investment adviser” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise clients for more information on the qualifications of our firm and our employees. Item 2: Material Changes Heritage Financial Counselors, LLC is required to make clients aware of information that has changed since the last annual update to the Firm Brochure (“Brochure”) and that may be important to them. Clients can then determine whether to review the brochure in its entirety or to contact us with questions about the changes. At this time, we have no changes to disclose. At this time, there are no material changes to report about the Brochure since the last annual amendment filed on March 11, 2025. Although not material, the Firm has made disclosure changes, enhancements and additions at Item 15, below. ADV Part 2A – Firm Brochure Page 2 Heritage Financial Counselors, LLC 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 & Compensation ..................................................................................................................... 7 Item 6: Performance-Based Fees & Side-By-Side Management .............................................................. 9 Item 7: Types of Clients & Account Requirements ................................................................................... 9 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ........................................................ 9 Item 9: Disciplinary Information .............................................................................................................. 14 Item 10: Other Financial Industry Activities & Affiliations .................................................................... 14 Item 11: Code of Ethics, Participation or Interest in .............................................................................. 14 Client Transactions & Personal Trading .................................................................................................. 15 Item 12: Brokerage Practices ................................................................................................................... 16 Item 13: Review of Accounts or Financial Plans ..................................................................................... 18 Item 14: Client Referrals & Other Compensation ................................................................................... 18 Item 15: Custody ....................................................................................................................................... 19 Item 16: Investment Discretion ............................................................................................................... 20 Item 17: Voting Client Securities .............................................................................................................. 20 Item 18: Financial Information ................................................................................................................ 21 ADV Part 2A – Firm Brochure Page 3 Heritage Financial Counselors, LLC Item 4: Advisory Business Our professional mission is to help individuals, couples and families develop holistic, comprehensive financial plans and asset management strategies. As Certified Financial Planner™ CFP®, professionals, we honor our fiduciary responsibility and are ethically bound to act in clients’ best interests. As independent financial advisors, we have no proprietary products to sell nor any corporate agenda to fulfill. Heritage Financial Counselors is a limited liability company formed under the laws of the State of New Jersey in 2016, and is wholly owned by Charles P. Weidman, CFP®, Managing Partner. Types of Advisory Services Offered GENERAL: Heritage Financial Counselors provides a variety of financial planning, investment management and consultation services. Financial Planning: Our integrated financial planning approach is designed to educate clients and to create a strategic collaboration regarding retirement planning, tax planning, multigenerational estate planning, insurance planning, and investment management, all within the context of their life plan/situation. Heritage Financial Counselors’ five-step financial planning process includes (1) discovering client financial goals and priorities, (2) analyzing client financial situation, (3) developing the financial plan, (4) implementing financial strategies, and (5) monitoring financial progress. Clients are provided summary reports (net worth, cash flow, retirement projections), detailed analysis where appropriate, and a secure login to access their financial planning information online. Financial plans generally include recommendations for a course of activity/action(s) to be taken by the client and by Heritage Financial Counselors, as appropriate. The Financial Planning & Consulting Agreement describes services, roles and responsibilities, including the fee arrangement. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested and engaged by the client to do so, Heritage Financial Counselors will generally provide financial planning and related consulting services regarding matters such as tax and estate planning, insurance, etc. per the terms and conditions of a separate agreement and a separate fee as discussed at Item 5 below, the fee for which shall generally be based upon the individual providing the service and the scope of the services to be provided. Prior to engaging Heritage Financial Counselors to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with Heritage Financial Counselors setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Heritage Financial Counselors commencing services. Clients recognize that the value and usefulness of Heritage Financial Counselors’ services will be dependent upon the information the client provides and the client’s active participation in the formulation and implementation of Planning objectives. We believe that it is important for the client ADV Part 2A – Firm Brochure Page 4 Heritage Financial Counselors, LLC to address financial planning issues on an ongoing basis. It remains each client’s responsibility to promptly notify Heritage Financial Counselors if there is ever any change in his/her/its financial situation or objectives. Investment Management: Investment management is the process of aligning the goals in a client’s financial plan/situation with targeted investment strategies. Our objective is to help clients clarify the purposes for their wealth, both near term and longer term. We then develop investment management strategies to help clients achieve their aims. We base our portfolio recommendations on client goals, time horizon and risk profile. Investment portfolios are primarily comprised of Exchange Traded Funds (ETFs) and no- load, low cost, asset-class mutual funds. Once a client’s asset allocation strategy is established, we utilize the operational, administrative, and information reporting services provided by Focus Partners. Heritage Financial Counselors provides non-discretionary investment advisory services on a fee basis as discussed at Item 5 below. The Wealth Advisory Agreement describes roles and responsibilities, as well as the fee arrangement. For individual retail (i.e., non-institutional) clients, Heritage Financial Counselors’ annual investment advisory fee shall generally (exceptions can occur-see below) include investment advisory services, and, to the extent specifically requested by the client, financial planning and consulting services. In the event that the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of Heritage Financial Counselors), Heritage Financial Counselors may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. Please Note: Non-Discretionary Service Limitations. Clients that determine to engage Heritage Financial Counselors on a non-discretionary investment advisory basis must be willing to accept that Heritage Financial Counselors cannot effect certain account transactions without express consent to such transaction(s) from the client. Thus, in the event that Heritage Financial Counselors would like to make a transaction for a client’s account, and client is unavailable, Heritage Financial Counselors may be unable to effect the account transaction (as it would for its discretionary clients) without first obtaining the client’s consent. Cash Positions. Heritage Financial Counselors continues to treat cash as an asset class. As such, unless determined to the contrary by Heritage Financial Counselors, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Heritage Financial Counselors’ advisory fee. Portfolio Activity. Heritage Financial Counselors has a fiduciary duty to provide services consistent with the client’s best interest. Heritage Financial Counselors will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Heritage Financial Counselors determines that changes to a client’s portfolio are unnecessary. Clients remain subject to the fees described in Item 5 below during periods of portfolio inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by the Heritage Financial Counselors will be profitable or equal any specific performance level(s). Other Assets. A client may: ADV Part 2A – Firm Brochure Page 5 Heritage Financial Counselors, LLC  hold securities that were purchased at the request of the client or acquired prior to the client’s engagement of Heritage Financial Counselors. Generally, with potential exceptions, Heritage Financial Counselors does not/would not recommend nor follow such securities, and absent mitigating tax consequences or client direction to the contrary, would prefer to liquidate such securities. Please Note: If/when liquidated, it should not be assumed that the replacement securities purchased by Heritage Financial Counselors will outperform the liquidated positions. To the contrary, different types of investments involve varying degrees of risk, and there can be no assurance that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Heritage Financial Counselors) will be profitable or equal any specific performance level(s)In addition, there may be other securities and/or accounts owned by the client for which Heritage Financial Counselors does not maintain custodian access and/or trading authority; and,  hold other securities and/or own accounts for which Heritage Financial Counselors does not maintain custodian access and/or trading authority. Corresponding Services/Fees: When agreed to by Heritage Financial Counselors, Heritage Financial Counselors shall: (1) remain available to discuss these securities/accounts on an ongoing basis at the request of the client; (2) monitor these securities/accounts on a regular basis, including, where applicable, rebalancing with client consent;(3) shall generally consider these securities as part of the client’s overall asset allocation; and, (4) report on such securities/accounts as part of regular reports that may be provided by Heritage Financial Counselors; and, (5) include the market value of all such securities for purposes of calculating advisory fee. Please Note: Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. We do not have or recommend an ESG strategy. WE DON’T RECOMMEND Cryptocurrency: For clients who want exposure to cryptocurrencies, including Bitcoin, Heritage Financial Counselors, will advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services, but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, a client must expressly authorize the purchase of the cryptocurrency investment. Please Note: Heritage Financial Counselors does not recommend or advocate the purchase of, or investment in, cryptocurrencies. The Registrant considers such an investment to be speculative. Please Also Note: Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal. for Client Obligations. In performing our services, Heritage Financial Counselors shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify Heritage Financial Counselors if there is ever any change in his/her/its financial situation or investment objectives the purpose of reviewing/evaluating/revising our previous recommendations and/or services. ADV Part 2A – Firm Brochure Page 6 Heritage Financial Counselors, LLC Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Heritage Financial Counselors) will be profitable or equal any specific performance level(s). Cybersecurity Risk. The information technology systems and networks that Heritage Financial Counselors and its third-party service providers use to provide services to Heritage Financial Counselors’ clients employ various controls that are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Heritage Financial Counselors’ operations and/or result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Heritage Financial Counselors are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur financial losses and/or other adverse consequences. Although Heritage Financial Counselors has established processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that Heritage Financial Counselors does not control the cybersecurity measures and policies employed by third-party service providers, issuers of securities, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchanges and other financial market operators and providers. Disclosure Brochure. A copy of Heritage Financial Counselors’ written Brochure as set forth on Part 2A of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each client prior to, or contemporaneously with, the execution of an agreement between the client and Heritage Financial Counselors. Tailoring of Advisory Services Our firm offers individualized investment advice to our Asset Management clients. We also tailor financial consulting engagements to meet specific situations, including estate settlements, business succession planning, or charitable giving strategies. Each Asset Management client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Participation in Wrap Fee Programs Our firm does not offer or sponsor a wrap fee program. Regulatory Assets Under Management As of December 31, 2024, our firm manages $201,217,560 on a non-discretionary basis. Item 5: Fees & Compensation Compensation for Our Advisory Services Asset Management: ADV Part 2A – Firm Brochure Page 7 Heritage Financial Counselors, LLC The maximum fee to be charged to the client for the services provided by our firm and Focus Partners will not exceed 2%. Fees to be assessed will be outlined in the advisory agreement to be signed by the Client. Our firm bills on cash unless indicated otherwise in writing. Annualized fees are billed on a pro-rata basis quarterly in advance, based upon the market value of such assets on the last day of the previous quarter, and are deducted from client account(s). Adjustments will be made for deposits and withdrawals, $10,000 or greater, during the quarter. In rare cases, our firm will agree to directly invoice. As part of this process, Clients understand the following: a) Focus Partners will calculate the advisory fees for all fee schedules and deduct them from the client’s account(s). Clients receive statements showing the fee amount, the value of the assets upon which the fee is based, and the specific manner in which the fee is calculated. b) Clients provide Focus Partners with written authorization permitting direct payment of advisory fees from their account(s) maintained by a custodian who is independent of our firm and Focus Partners; and c) The account custodian sends a statement to the client showing all account disbursements, including advisory fees. Financial Planning & Consulting: Our firm charges on a flat fee basis for financial planning and consulting services. The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with the client. Flat fees will not exceed $15,000. Our firm requires a retainer of 50% of the ultimate financial planning or consulting fee at the time of signing. The remainder of the fee will be directly billed to the client and due within 30 days of a financial plan being delivered or consultation rendered. Our firm will not require a retainer exceeding $1,200 when services cannot be rendered within 6 months. Other Types of Fees & Expenses Clients will incur transaction charges for trades executed in their accounts. These transaction fees are separate from our firm’s advisory fees and will be disclosed by the chosen custodian. Charles Schwab & Co. Inc. (“Schwab”), does not charge transaction fees for U.S. listed equities and exchange traded funds. Clients may also pay charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses). Our firm does not receive a portion of these fees. Clients may also be invested in other mutual funds (“DFA Funds”) managed by Dimensional Fund Advisors, Inc. (“DFA”), a third-party investment adviser that is unaffiliated with our firm and Focus Partners. Clients may also pay holdings charges imposed by the chosen custodian for certain investments, charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (e.g., fund management fees, distribution fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, mark-ups and mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions). Our firm does not receive a portion of these fees. Termination & Refunds ADV Part 2A – Firm Brochure Page 8 Heritage Financial Counselors, LLC The Focus Partners Structured Investing Advantage Agreement may be terminated in writing at any time. Upon notice of termination a pro-rata refund of the unearned portion of the advisory fees charged in advance at the beginning of the quarter will be processed. Financial Planning & Consulting clients may terminate their agreement at any time before the delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work performed by us up to the point of termination shall be calculated at the hourly fee currently in effect. Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our firm. Commissionable Securities Sales Our firm and representatives do not sell securities for a commission in advisory accounts. Item 6: Performance-Based Fees & Side-By-Side Management Our firm does not charge performance-based fees. Item 7: Types of Clients & Account Requirements Our firm has the following types of clients: Individuals and High Net Worth Individuals;   Trusts or Estates;  Corporations, Limited Liability Companies and/or Other Business Types. Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging us. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss The following methods of analysis and investment strategies may be utilized in formulating our investment advice and/or managing client assets, provided that such methods and/or 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. General Risks of Owning Securities The prices of securities held in client accounts and the income they generate may decline in response to certain events taking place around the world. These include events directly involving the issuers ADV Part 2A – Firm Brochure Page 9 Heritage Financial Counselors, LLC of securities held as underlying assets of mutual funds in a client’s account, conditions affecting the general economy, and overall market changes. Other contributing factors include local, regional, or global political, social, or economic instability and governmental or governmental agency responses to economic conditions. Finally, currency, interest rate, and commodity price fluctuations may also affect security prices and income. The prices of, and the income generated by, most debt securities held by a client’s account may be affected by changing interest rates and by changes in the effective maturities and credit ratings of these securities. For example, the prices of debt securities in the client’s account generally will decline when interest rates rise and increase when interest rates fall. In addition, falling interest rates may cause an issuer to redeem, “call” or refinance a security before its stated maturity, which may result in our firm having to reinvest the proceeds in lower yielding securities. Longer maturity debt securities generally have higher rates of interest and may be subject to greater price fluctuations than shorter maturity debt securities. Debt securities are also subject to credit risk, which is the possibility that the credit strength of an issuer will weaken and/or an issuer of a debt security will fail to make timely payments of principal or interest and the security will go into default. The guarantee of a security backed by the U.S. Treasury or the full faith and credit of the U.S. government only covers the timely payment of interest and principal when held to maturity. This means that the current market values for these securities will fluctuate with changes in interest rates. Investments in securities issued by entities based outside the United States may be subject to increased levels of the risks described above. Currency fluctuations and controls, different accounting, auditing, financial reporting, disclosure, regulatory and legal standards and practices could also affect investments in securities of foreign issuers. Additional factors may include expropriation, changes in tax policy, greater market volatility, different securities market structures, and higher transaction costs. Various administrative difficulties, such as delays in clearing and settling portfolio transactions, or in receiving payment of dividends can increase risk. Finally, investments in securities issued by entities domiciled in the United States may also be subject to many of these risks. Mutual Fund and/or Exchange Traded Fund Analysis: Analysis of the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. The underlying assets in a mutual fund or ETF are also reviewed in an attempt to determine if there is significant overlap in the underlying investments held in another fund(s) in the Client’s portfolio. The funds or ETFs are monitored 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 our firm does 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(s) less suitable for the Client’s portfolio. Third-Party Money Manager Analysis: The analysis of the experience, investment philosophies, and past performance of independent third-party investment managers in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. Analysis is completed by monitoring the manager’s underlying holdings, strategies, ADV Part 2A – Firm Brochure Page 10 Heritage Financial Counselors, LLC concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of the due-diligence process, the manager’s compliance and business enterprise risks are surveyed and reviewed. A risk of investing with a third-party manager who has been successful in the past is that they may not be able to replicate that success in the future. In addition, as our firm does not control the underlying investments in a third-party manager’s portfolio, there is also a risk that a manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. Moreover, as our firm does not control the manager’s daily business and compliance operations, our firm may be unaware of the lack of internal controls necessary to prevent business, regulatory or reputational deficiencies. Exchange Traded Funds: An ETF is a type of Investment Company (usually, an open-end fund or unit investment trust) whose primary objective is to achieve the same return as a particular market index. The vast majority of ETFs are designed to track an index, so their performance is close to that of an index mutual fund, but they are not exact duplicates. A tracking error, or the difference between the returns of a fund and the returns of the index, can arise due to differences in composition, management fees, expenses, and handling of dividends. ETFs benefit from continuous pricing; they can be bought and sold on a stock exchange throughout the trading day. Because ETFs trade like stocks, you can place orders just like with individual stocks - such as limit orders, good-until-canceled orders, stop loss orders etc. They can also be sold short. Traditional mutual funds are bought and redeemed based on their net asset values (“NAV”) at the end of the day. ETFs are bought and sold at the market prices on the exchanges, which resemble the underlying NAV but are independent of it. However, arbitrageurs will ensure that ETF prices are kept very close to the NAV of the underlying securities. Although an investor can buy as few as one share of an ETF, most buy in board lots. Anything bought in less than a board lot will increase the cost to the investor. Anyone can buy any ETF no matter where in the world it trades. This provides a benefit over mutual funds, which generally can only be bought in the country in which they are registered. One of the main features of ETFs are their low annual fees, especially when compared to traditional mutual funds. The passive nature of index investing, reduced marketing, and distribution and accounting expenses all contribute to the lower fees. However, individual investors must pay a brokerage commission to purchase and sell ETF shares; for those investors who trade frequently, this can significantly increase the cost of investing in ETFs. That said, with the advent of low-cost brokerage fees, small or frequent purchases of ETFs are becoming more cost efficient. Fixed Income: Fixed income is a type of investing or budgeting style for which real return rates or periodic income is received at regular intervals and at reasonably predictable levels. Fixed-income investors are typically retired individuals who rely on their investments to provide a regular, stable income stream. This demographic tends to invest heavily in fixed-income investments because of the reliable returns they offer. Fixed-income investors who live on set amounts of periodically paid income face the risk of inflation eroding their spending power. Some examples of fixed-income investments include treasuries, money market instruments, corporate bonds, asset-backed securities, municipal bonds and international bonds. The primary risk associated with fixed-income investments is the borrower defaulting on his payment. Other considerations include exchange rate risk for international bonds and interest rate risk for longer- dated securities. The most common type of fixed-income security is a bond. Bonds are issued by federal governments, local municipalities and major corporations. Fixed-income securities are recommended for investors seeking a diverse portfolio; however, the percentage of the portfolio dedicated to fixed income depends on your own personal investment style. There is also an opportunity to diversify the fixed-income component of a portfolio. Riskier fixed-income products, ADV Part 2A – Firm Brochure Page 11 Heritage Financial Counselors, LLC such as junk bonds and longer-dated products, should comprise a lower percentage of your overall portfolio. The interest payment on fixed-income securities is considered regular income and is determined based on the creditworthiness of the borrower and current market rates. In general, bonds and fixed- income securities with longer-dated maturities pay a higher rate, also referred to as the coupon rate, because they are considered riskier. The longer the security is on the market, the more time it has to lose its value and/or default. At the end of the bond term, or at bond maturity, the borrower returns the amount borrowed, also referred to as the principal or par value. Individual Stocks: A common stock is a security that represents ownership in a corporation. Holders of common stock exercise control by electing a board of directors and voting on corporate policy. Investing in individual common stocks provides us with more control of what you are invested in and when that investment is made. Having the ability to decide when to buy or sell helps us time the taking of gains or losses. Common stocks, however, bear a greater amount of risk when compared to certificate of deposits, preferred stock and bonds. It is typically more difficult to achieve diversification when investing in individual common stocks. Additionally, common stockholders are on the bottom of the priority ladder for ownership structure; if a company goes bankrupt, the common stockholders do not receive their money until the creditors and preferred shareholders have received their respective share of the leftover assets. Interval Funds: Interval funds can expose investors to liquidity risk, and that risk is greater in funds that invest in securities of companies with smaller market capitalizations, derivatives or securities with substantial market and/or credit risk. Even though interval funds make periodic offers to repurchase a portion of outstanding shares, investors should consider interval fund shares to be an illiquid investment. There is no guarantee that investors will be able to sell interval fund shares at any given time or in the quantity that they desire. The price that shareholders will receive on a repurchase will be based on the per share NAV determined as of a specified date. This date will occur sometime after the close of business on the date that shareholders must submit their acceptances of the repurchase offer so investor may not know the exact price they will receive for their redemption when effecting the transaction. Additionally, this price may be subject to a redemption fee that further erodes the value of the position upon redemption. Focus Partners DFA Funds: Our firm may instruct Focus Partners to purchase shares of the DFA Funds for the client’s Structured Investing Advantage account in accordance with client’s instructions. Neither the client nor our firm will be entitled to any rebate, credit or waiver of fees received by Focus Partners in connection with Focus Partners' services to the DFA Funds. Mutual Funds: A mutual fund is a company that pools money from many investors and invests the money in a variety of differing security types based the objectives of the fund. The portfolio of the fund consists of the combined holdings it owns. Each share represents an investor’s proportionate ownership of the fund’s holdings and the income those holdings generate. The price that investors pay for mutual fund shares is the fund’s per share net asset value (“NAV”) plus any shareholder fees that the fund imposes at the time of purchase (such as sales loads). Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given time, nor can they directly influence which securities the fund manager buys and sells or the timing of those trades. With an individual stock, investors can obtain real-time (or close to real-time) pricing information with relative ease by checking financial websites or by calling a broker or your investment adviser. Investors can also monitor how a stock’s price changes from hour to hour—or even second to second. By contrast, with a mutual fund, the price at which an investor purchases or redeems shares will typically depend on the fund’s NAV, which is calculated daily after market close. ADV Part 2A – Firm Brochure Page 12 Heritage Financial Counselors, LLC The benefits of investing through mutual funds include: (a) Mutual funds are professionally managed by an investment adviser who researches, selects, and monitors the performance of the securities purchased by the fund; (b) Mutual funds typically have the benefit of diversification, which is an investing strategy that generally sums up as “Don’t put all your eggs in one basket.” Spreading investments across a wide range of companies and industry sectors can help lower the risk if a company or sector fails. Some investors find it easier to achieve diversification through ownership of mutual funds rather than through ownership of individual stocks or bonds.; (c) Some mutual funds accommodate investors who do not have a lot of money to invest by setting relatively low dollar amounts for initial purchases, subsequent monthly purchases, or both.; and (d) At any time, mutual fund investors can readily redeem their shares at the current NAV, less any fees and charges assessed on redemption. Mutual funds also have features that some investors might view as disadvantages: (a) Investors must pay sales charges, annual fees, and other expenses regardless of how the fund performs. Depending on the timing of their investment, investors may also have to pay taxes on any capital gains distribution they receive. This includes instances where the fund went on to perform poorly after purchasing shares.; (b) Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given time, nor can they directly influence which securities the fund manager buys and sells or the timing of those trades.; and (c) With an individual stock, investors can obtain real-time (or close to real-time) pricing information with relative ease by checking financial websites or by calling a broker or your investment adviser. Investors can also monitor how a stock’s price changes from hour to hour—or even second to second. By contrast, with a mutual fund, the price at which an investor purchases or redeems shares will typically depend on the fund’s NAV, which the fund might not calculate until many hours after the investor placed the order. In general, mutual funds must calculate their NAV at least once every business day, typically after the major U.S. exchanges close. When investors buy and hold an individual stock or bond, the investor must pay income tax each year on the dividends or interest the investor receives. However, the investor will not have to pay any capital gains tax until the investor actually sells and makes a profit. Mutual funds are different. When an investor buys and holds mutual fund shares, the investor will owe income tax on any ordinary dividends in the year the investor receives or reinvests them. Moreover, in addition to owing taxes on any personal capital gains when the investor sells shares, the investor may have to pay taxes each year on the fund’s capital gains. That is because the law requires mutual funds to distribute capital gains to shareholders if they sell securities for a profit, and cannot use losses to offset these gains. Cash and/or Cash Equivalents: Focus Partners generally invests client cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our firm tries to achieve the highest return on client cash balances through relatively low-risk conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that Focus Partners may debit advisory fees for our services related to our Asset Management services, as applicable. Other Assets. A client may:  hold securities that were purchased at the request of the client or acquired prior to the client’s engagement of the Heritage Financial Counselors. Generally, with potential exceptions, the Heritage Financial Counselors does not/would not recommend nor follow such securities, and absent mitigating tax consequences or client direction to the contrary, would prefer to liquidate such securities. Please Note: If/when liquidated, it should not be assumed that the ADV Part 2A – Firm Brochure Page 13 Heritage Financial Counselors, LLC replacement securities purchased by the Heritage Financial Counselors will outperform the liquidated positions. To the contrary, different types of investments involve varying degrees of risk, and there can be no assurance that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by the Heritage Financial Counselors) will be profitable or equal any specific performance level(s)In addition, there may be other securities and/or accounts owned by the client for which the Heritage Financial Counselors does not maintain custodian access and/or trading authority; and,  hold other securities and/or own accounts for which the Heritage Financial Counselors does not maintain custodian access and/or trading authority. ANY QUESTIONS: The Heritage Financial Counselors’ Chief Compliance Officer, Charlie P. Weidman, remains available to address any questions regarding the above. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and the account(s) could enjoy a gain, it is also possible that the stock market may decrease and the account(s) could suffer a loss. It is important that clients understand the risks associated with investing in the stock market, are appropriately diversified in investments, and ask any questions. Item 9: Disciplinary Information There are no legal or disciplinary events that are material to the evaluation of our advisory business or the integrity of our management. Item 10: Other Financial Industry Activities & Affiliations As indicated at Item 4 above, Heritage Financial Counselors does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, Heritage Financial Counselors does not prepare legal documents, prepare tax returns, or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for non-investment implementation purpose (i.e., attorneys, accountants, insurance, etc.) Our firm is not registered, nor does it have an application pending to register, as a broker-dealer, registered representative of a broker dealer, investment company or pooled investment vehicle, other investment adviser or financial planner, futures commission merchant, commodity pool operator, commodity trading advisor, banking or thrift institution, accountant or accounting firm, lawyer or law firm, insurance company or agency, pension consultant, real estate broker or dealer or a sponsor or syndicator of limited partnership, or an associated person of the foregoing entities. Our firm has no other financial industry affiliations to disclose. Item 11: Code of Ethics, Participation or Interest in ADV Part 2A – Firm Brochure Page 14 Heritage Financial Counselors, LLC Client Transactions & Personal Trading As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty is the underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities transaction and insider trading. Our firm requires all representatives to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment with our firm, and at least annually thereafter, all representatives of our firm will acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. Our firm recognizes that the personal investment transactions of our representatives demands the application of a Code of Ethics with high standards and requires that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, our firm also believes that if investment goals are similar for clients and for our representatives, it is logical, and even desirable, that there be common ownership of some securities. In order to prevent conflicts of interest, our firm has established procedures for transactions effected by our representatives for their personal accounts1. In order to monitor compliance with our personal trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting system for all of our representatives. Neither our firm nor a related person recommends, buys or sells for client accounts, securities in which our firm or a related person has a material financial interest without prior disclosure to the client. Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying or selling the same securities prior to buying or selling for our clients in the same day unless included in a block trade. Please Note: Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, 1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse, his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect beneficial interest in. ADV Part 2A – Firm Brochure Page 15 Heritage Financial Counselors, LLC depending upon the client’s age, result in adverse tax consequences). If Heritage Financial Counselors recommends that a client roll over their retirement plan assets into an account to be managed by Heritage Financial Counselors, such a recommendation creates a conflict of interest if Heritage Financial Counselors will earn new (or increase its current) compensation as a result of the rollover. If Heritage Financial Counselors provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Heritage Financial Counselors is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by Heritage Financial Counselors, whether it is from an employer’s plan or an existing IRA. Heritage Financial Counselors’ Chief Compliance Officer, Charles P. Weidman, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Cybersecurity Risk. The information technology systems and networks that Heritage Financial Counselors and its third-party service providers use to provide services to Heritage Financial Counselors’ clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Heritage Financial Counselors’ operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Heritage Financial Counselors are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although Heritage Financial Counselors has established processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that Heritage Financial Counselors does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Item 12: Brokerage Practices Selecting a Brokerage Firm As part of our Asset Management and Referrals to Third Party Money Managers services, our firm may recommend the services provided by Focus Partners. Our firm participates in the Schwab Institutional program and recommends it to clients. Schwab Institutional is a division of Charles Schwab & Co. Inc. (“Schwab”) member FINRA/SIPC. Schwab is an independent [and unaffiliated] SEC-registered broker-dealer. Schwab offers services to independent investment advisers which includes custody of securities, trade execution, clearance and settlement of transactions. Schwab enables us to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Schwab does not charge client accounts separately for custodial services. Client accounts will be charged transaction fees, commissions or other fees on trades that are executed or settle into the client’s custodial account. Transaction fees are ADV Part 2A – Firm Brochure Page 16 Heritage Financial Counselors, LLC negotiated with Schwab and are generally discounted from customary retail commission rates. This benefits clients because the overall fee paid is often lower than would be otherwise. Research and Benefits: Although not a material consideration when determining whether to recommend that a client utilize the services of a particular broker-dealer/custodian, Heritage Financial Counselors can receive from Schwab (or another broker-dealer/custodian, investment manager, platform sponsor, mutual fund sponsor, or vendor) without cost (and/or at a discount) support services and/or products, certain of which assist Heritage Financial Counselors to better monitor and service client accounts maintained at such institutions. Included within the support services that can be obtained by Heritage Financial Counselors can be investment-related research, pricing information and market data, software and other technology that provide access to client account data, compliance and/or practice management-related publications, discounted or gratis consulting services (including those provided by unaffiliated vendors and professionals), discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support (including client events), computer hardware and/or software and/or other products used by Heritage Financial Counselors in furtherance of its investment advisory business operations. Certain of the benefits that could be received can also assist Heritage Financial Counselors to manage and further develop its business enterprise and/or benefit Heritage Financial Counselors’ representatives. Heritage Financial Counselors’ clients do not pay more for investment transactions effected and/or assets maintained at Schwab as the result of this arrangement. There is no corresponding commitment made by Heritage Financial Counselors to Schwab, or any other any entity, to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as result of the above arrangement. ANY QUESTIONS: Heritage Financial Counselors’ Chief Compliance Officer, Name of CCO, remains available to address any questions that a client or prospective client may have regarding the above arrangements and the corresponding conflicts of interest presented by such arrangements. Directed Brokerage. Heritage Financial Counselors recommends that its clients utilize the brokerage and custodial services provided by Schwab. The Firm generally does not accept directed brokerage arrangements (but could make exceptions). A directed brokerage arrangement arises when a client requires that account transactions be effected through a specific broker- dealer/custodian, other than one generally recommended by Heritage Financial Counselors (i.e., Schwab). In such client directed arrangements, the client will negotiate terms and arrangements for their account with that broker-dealer, and Firm will not seek better execution services or prices from other broker-dealers or be able to "batch" the client’s transactions for execution through other broker-dealers with orders for other accounts managed by Heritage Financial Counselors. As a result, a client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. Please Note: In the event that the client directs Heritage Financial Counselors to effect securities transactions for the client’s accounts through a specific broker-dealer, the client correspondingly acknowledges that such direction 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 Heritage Financial Counselors. Please Also Note: Higher transaction costs adversely impact account performance. Please Further Note: Transactions for directed accounts will generally be executed following the execution of portfolio transactions for non-directed accounts. ADV Part 2A – Firm Brochure Page 17 Heritage Financial Counselors, LLC Soft Dollars Our firm does not receive soft dollars in excess of what is allowed by Section 28(e) of the Securities Exchange Act of 1934. The safe harbor research products and services obtained by our firm will generally be used to service all of our clients but not necessarily all at any one particular time. Aggregation of Purchase or Sale Focus Partners and DFA provide investment management services for various clients. There are occasions on which portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same security for numerous accounts served, which involve accounts with similar investment objectives. Although such concurrent authorizations potentially could be either advantageous or disadvantageous to any one or more particular accounts, they are affected only when it is believed that to do so will be in the best interest of the effected accounts. When such concurrent authorizations occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts involved. In any given situation, our firm attempts to allocate trade executions in the most equitable manner possible, taking into consideration client objectives, current asset allocation and availability of funds using price averaging, proration and consistently non-arbitrary methods of allocation. Item 13: Review of Accounts or Financial Plans Our Financial Counselors and/or Professional Staff review accounts on at least an annual basis for our Asset Management clients. The nature of these reviews is to learn whether client accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Our firm does not provide written reports to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis. Our firm may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. Our firm provides ongoing services to Financial Planning clients, and are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Financial Planning clients receive updated reports regarding their financial plans. Item 14: Client Referrals & Other Compensation Our firm may recommend Schwab to clients for custody and brokerage services. There is no direct link between our firm’s participation in the program and the investment advice given to clients, although we receive economic benefits through our participation in the program that are typically not available to Schwab retail investors. These benefits include the following products and services (provided without cost or at a discount): receipt of duplicate client statements and confirmations; research related products and tools; consulting services; access to a trading desk serving our firm’s participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts); the ability to have advisory ADV Part 2A – Firm Brochure Page 18 Heritage Financial Counselors, LLC fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to us by third party vendors. Schwab may also have paid for business consulting and professional services received by our firm’s related persons. Some of the products and services made available by Schwab through the program may benefit our firm but may not benefit our client accounts. These products or services may assist us in managing and administering client accounts, including accounts not maintained at Schwab. Other services made available by Schwab are intended to help us manage and further develop our business enterprise. The benefits received by our firm or our personnel through participation in the program do not depend on the amount of brokerage transactions directed to Schwab. As part of our fiduciary duties to our clients, we endeavor at all times to put the interests of our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm or our related persons in and of itself creates a potential conflict of interest and may indirectly influence our firm’s choice of Schwab for custody and brokerage services. Referral Fees In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which include client referrals). Item 15: Custody Our firm does not have custody of client funds or securities. All of our clients receive account statements directly from their qualified custodians at least quarterly upon opening of an account. Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. Heritage Financial Counselors and/or Focus Partners shall have the ability to deduct its advisory fee from the client’s custodial account. Clients are provided with written transaction confirmation notices, and a written summary account statement directly from the custodian (i.e., Schwab, etc.) at least quarterly. Please Note: To the extent that Heritage Financial Counselors and/or Focus Partners provides clients with periodic account statements or reports, the client is urged to compare any statement or report provided by Heritage Financial Counselors and/or Focus Partners with the account statements received from the account custodian. Please Also Note: The account custodian does not verify the accuracy of Heritage Financial Counselors’ and/or Focus Partners advisory fee calculation. Custodian Charges-Additional Fees. As discussed above at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Heritage Financial Counselors generally recommends that Schwab serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Schwab charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian. While certain custodians, including Schwab, generally (with exceptions) do not currently charge fees on ADV Part 2A – Firm Brochure Page 19 Heritage Financial Counselors, LLC individual equity transactions (including ETFs), others do. Please Note: there can be no assurance that Schwab will not change its transaction fee pricing in the future. Please Also Note: Schwab may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. ANY QUESTIONS: Heritage Financial Counselors’ Chief Compliance Officer, Charles P. Weidman, remains available to address any questions that a client or prospective client may have regarding the above. Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion, Heritage Financial Counselors shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless Heritage Financial Counselors reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. Please Note: The above does not apply to the cash component maintained within a Heritage Financial Counselors actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager, and cash balances maintained for fee billing purposes. Please Also Note: The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any Heritage Financial Counselors unmanaged accounts. ANY QUESTIONS: Heritage Financial Counselors’ Chief Compliance Officer, Charlie P. Weidman, remains available to address any questions that a client or prospective client may have regarding the above. Item 16: Investment Discretion Clients have the option of providing our firm with investment discretion on their behalf, pursuant to an executed investment advisory client agreement. By granting investment discretion, our firm is authorized to execute securities transactions, determine which securities are bought and sold, and the total amount to be bought and sold. Limitations may be imposed by the client in the form of specific constraints on any of these areas of discretion with our firm’s written acknowledgement. Item 17: Voting Client Securities Our firm does not accept the proxy authority to vote client securities. Clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities owned by the client shall be voted; and (2) making all elections, decisions, and filings relative to any mergers, ADV Part 2A – Firm Brochure Page 20 Heritage Financial Counselors, LLC acquisitions, tender offers, bankruptcy proceedings, class actions, or other type actions or events pertaining to the client’s investment assets. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, our firm will forward them to the appropriate client and ask the party who sent them to mail them directly to the client in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. Item 18: Financial Information Our firm has never been the subject of a bankruptcy proceeding. Our firm is not required to provide financial information in this Brochure because:  Our firm does not require the prepayment of more than $1,200 in fees when services cannot be rendered within 6 months.  Our firm does not take custody of client funds or securities.  Our firm does not have a financial condition or commitment that impairs our ability to meet contractual and fiduciary obligations to clients. Our firm has obtained financial assistance by participating in Paycheck Protection Program (“PPP”) established by the U.S. Small Business Administration (“SBA”). PPP is intended to assist us with maintaining our firm’s business in response to the COVID-19 pandemic by providing low-interest loans for business essentials such as payroll expenses. These loans are eligible for forgiveness, which our firm received. ADV Part 2A – Firm Brochure Page 21 Heritage Financial Counselors, LLC