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Item 1 Cover Page
D I S C L O S U R E B R O C H U R E
F O R M A D V P A R T 2 A
Office Address:
8935 Ortega Road
Atascadero, CA 93422
Tel: (530) 400-4851
Web: www.hewellfinancial.com
January 29, 2026
This brochure provides information about the qualifications and business practices of Hewell
Financial Group, Inc.. Being registered as a registered investment adviser does not imply a certain
level of skill or training. If you have any questions about the contents of this brochure, please contact
us at (530) 400-4851. The information in this brochure has not been approved or verified by the
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United States Securities and Exchange Commission, or by any state securities authority.
ADDITIONAL INFORMATION ABOUT HEWELL FINANCIAL GROUP, INC. (CRD#333535) IS
AVAILABLE ON THE SEC’S WEBSITE AT WWW.ADVISERINFO.SEC.GOV.
Item 2: Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure.
Material Changes since the Last Update
Since the last update of this brochure on February 5, 2025 the following changes have
occurred:
• Cover pages to update the address.
•
Item 4 assets under management calculation updated.
Full Brochure Available
This Firm Brochure being delivered is the complete brochure for the Firm.
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Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Item 2: Material Changes .................................................................................................................... ii
Annual Update ................................................................................................................................................. ii
Material Changes since the Last Update ............................................................................................... ii
Full Brochure Available ............................................................................................................................... ii
Item 3: Table of Contents ................................................................................................................... iii
Item 4: Advisory Business .................................................................................................................. 1
Firm Description ............................................................................................................................................ 1
Types of Advisory Services ........................................................................................................................ 1
Client Tailored Services and Client Imposed Restrictions ............................................................. 5
Wrap Fee Programs ...................................................................................................................................... 5
Client Assets under Management ............................................................................................................ 5
Item 5: Fees and Compensation ....................................................................................................... 5
Method of Compensation and Fee Schedule........................................................................................ 5
Client Payment of Fees ................................................................................................................................. 7
Additional Client Fees Charged ................................................................................................................ 7
Prepayment of Client Fees .......................................................................................................................... 7
External Compensation for the Sale of Securities to Clients ......................................................... 7
Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 8
Sharing of Capital Gains ............................................................................................................................... 8
Item 7: Types of Clients ....................................................................................................................... 8
Description ....................................................................................................................................................... 8
Account Minimums ....................................................................................................................................... 8
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 8
Methods of Analysis ...................................................................................................................................... 8
Investment Strategy ...................................................................................................................................... 9
Security Specific Material Risks ............................................................................................................... 9
Item 9: Disciplinary Information ................................................................................................... 10
Criminal or Civil Actions ...........................................................................................................................10
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Administrative Enforcement Proceedings .........................................................................................10
Self-Regulatory Organization Enforcement Proceedings .............................................................10
Item 10: Other Financial Industry Activities and Affiliations ............................................. 10
Broker-Dealer or Representative Registration ................................................................................10
Futures or Commodity Registration .....................................................................................................10
Material Relationships Maintained by this Advisory Business and Conflicts of Interest 10
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest11
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ................................................................................................................................................... 11
Code of Ethics Description .......................................................................................................................11
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest .............................................................................................................................................................11
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest .............................................................................................................................................................12
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Transactions and Conflicts of Interest .................................................................................................12
Item 12: Brokerage Practices ......................................................................................................... 12
Factors Used to Select Broker-Dealers for Client Transactions .................................................12
Aggregating Securities Transactions for Client Accounts ............................................................14
Item 13: Review of Accounts ........................................................................................................... 14
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved ..........................................................................................................................................14
Review of Client Accounts on Non-Periodic Basis ..........................................................................14
Content of Client Provided Reports and Frequency .......................................................................14
Item 14: Client Referrals and Other Compensation ................................................................ 14
Economic benefits Provided to the Advisory Firm from External Sources and Conflicts of
Interest .............................................................................................................................................................14
Advisory Firm Payments for Client Referrals ...................................................................................16
Item 15: Custody .................................................................................................................................. 16
Account Statements ....................................................................................................................................16
Item 16: Investment Discretion ..................................................................................................... 16
Discretionary Authority for Trading ....................................................................................................16
Item 17: Voting Client Securities ................................................................................................... 17
Proxy Votes ....................................................................................................................................................17
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Item 18: Financial Information ...................................................................................................... 17
Balance Sheet .................................................................................................................................................17
Bankruptcy Petitions during the Past Ten Years .............................................................................17
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 19
Principal Executive Officer .......................................................................................................................19
Kaitlin (“Kate”) Hewell...............................................................................................................................19
Item 2 Educational Background and Business Experience .........................................................19
Professional Certifications .......................................................................................................................19
Item 3 Disciplinary Information ............................................................................................................20
Item 4 Other Business Activities ............................................................................................................20
Item 5 Additional Compensation ...........................................................................................................21
Item 6 Supervision ......................................................................................................................................21
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Item 4: Advisory Business
Firm Description
Hewell Financial Group, Inc. (“HFG” or “we”) is dedicated to providing individuals and
other types of clients with a wide array of investment advisory services. We specialize in
comprehensive asset management and financial planning and consulting. Hewell Financial
Group, Inc. was formed in 2012, began offering advisory services in 2025 and is owned by
Kaitlin Hewell.
Types of Advisory Services
ASSET MANAGEMENT
HFG offers discretionary asset management services to advisory Clients. HFG will offer
Clients ongoing asset 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. The Client will authorize HFG discretionary authority to
execute selected investment program transactions as stated within the Investment
Advisory Agreement.
Additionally, we may offer discretionary asset management services to Clients by selecting
the AssetMark Platform. For more information regarding the AssetMark Platform, refer to
AssetMark Platform Disclosure Brochure.
The minimum investment required on the AssetMark Platform depends upon the
Investment Solution chosen for a Client’s account and is generally $25,000 - $50,000 for
Mutual Fund and $100,000 for ETF Accounts, and from $50,000 to $500,000 for Privately
Managed and Unified Managed Accounts, depending on the investment strategy selected
for the account. These minimums are described in more detail in the AssetMark Platform
Disclosure Brochure. Accounts below the stated minimums may be accepted on an
individual basis at the discretion of AssetMark.
ERISA PLAN SERVICES
We provide service to qualified retirement plans including 401(k) plans, 403(b) plans,
pension and profit sharing plans, cash balance plans, and deferred compensation plans. We
may act as a 3(21) or 3(38) adviser:
Limited Scope ERISA 3(21) Fiduciary. HFG may serve as a limited scope ERISA 3(21)
fiduciary that can advise, help and assist plan sponsors with their investment decisions on
a non-discretionary basis. As an investment adviser, we have a fiduciary duty to act in the
best interest of the Client. The plan sponsor is still ultimately responsible for the decisions
made in their plan, though using us can help the plan sponsor delegate liability by following
a diligent process.
1. Fiduciary Services are:
• Provide non-discretionary investment advice to the Client about asset classes and
investment alternatives available for the Plan in accordance with the Plan’s investment
policies and objectives. Client will make the final decision regarding the initial selection,
retention, removal and addition of investment options. HFG acknowledges that it is a
fiduciary as defined in ERISA section 3 (21) (A) (ii).
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• Assist the Client in the development of an investment policy statement (“IPS”). The IPS
establishes the investment policies and objectives for the Plan. Client shall have the
ultimate responsibility and authority to establish such policies and objectives and to
adopt and amend the IPS.
• Provide non-discretionary investment advice to the Plan Sponsor with respect to the
selection of a qualified default investment alternative for participants who are
automatically enrolled in the Plan or who have otherwise failed to make investment
elections. The Client retains the sole responsibility to provide all notices to the Plan
participants required under ERISA Section 404(c) (5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports that
document investment performance, consistency of fund management and conformance
to the guidelines set forth in the IPS and make recommendations to maintain, remove
or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and
the investment alternatives available to them under the Plan. Client understands our
assistance in education of the Plan participants shall be consistent with and within the
scope of the Department of Labor’s definition of investment education (Department of
Labor Interpretive Bulletin 96-1). As such, we are not providing fiduciary advice as
defined by ERISA 3(21)(A)(ii) to the Plan participants. We will not provide investment
advice concerning the prudence of any investment option or combination of investment
options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by the
employees.
We may provide these services or, alternatively, may arrange for the Plan’s other providers
to offer these services, as agreed upon between HFG and Client.
3. We have no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
• Other hard-to-value or illiquid securities or property.
ERISA 3(38) Investment Manager. HFG can also act as an ERISA 3(38) Investment
Manager in which it has discretionary management and control of a given retirement plan’s
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assets. HFG would then become solely responsible and liable for the selection, monitoring
and replacement of the plan’s investment options.
1. Fiduciary Services are:
• HFG has discretionary authority and will make the final decision regarding the
initial selection, retention, removal and addition of investment options in
accordance with the Plan’s investment policies and objectives.
• Assist the Client with the selection of a broad range of investment options consistent
with ERISA Section 404(c) and the regulations thereunder.
• Assist the Client in the development of an investment policy statement (“IPS”). The
IPS establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the
selection of a qualified default investment option for participants who are
automatically enrolled in the Plan or who have otherwise failed to make investment
elections. The Client retains the sole responsibility to provide all notices to the Plan
participants required under ERISA Section 404(c) (5).
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information
and the investment options available to them under the Plan. Client understands the
HFG’s assistance in education of the Plan participants shall be consistent with and
within the scope of the Department of Labor’s definition of investment education
(Department of Labor Interpretive Bulletin 96-1). As such, the HFG is not providing
fiduciary advice as defined by ERISA to the Plan participants. HFG will not provide
investment option or
investment advice concerning the prudence of any
combination of investment options for a particular participant or beneficiary under
the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by
the employees.
HFG may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between HFG and Client.
3. HFG has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
• Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to us on the ERISA
Agreement.
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Specific services will be outlined in detail to each plan in the 408(b)2 disclosure.
FINANCIAL PLANNING AND CONSULTING
We provide financial planning services as a comprehensive evaluation of a client’s current
and future financial state by using currently known variables to predict future cash flows,
asset values and withdrawal plans. The plan is an ongoing process with the time period
outlined in the contract. Through the financial planning process, all questions, information
and analysis are considered as they impact and are impacted by the entire financial and life
situation of the client. Clients purchasing this service receive a written report which
provides the client with a detailed financial plan designed to assist the client achieve his or
her financial goals and objectives.
In general, the financial plan can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate
information and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax and spending and planning
for past, current and future years; then illustrate the impact of various investments
on the client’s income tax and future tax liability.
•
INVESTMENTS: We analyze investment alternatives and their effect on the client’s
portfolio.
•
INSURANCE: We review existing policies to ensure proper coverage for life, health,
disability, long-term care, liability, home and automobile.
• RETIREMENT: We analyze current strategies and investment plans to help the
client achieve his or her retirement goals.
• DEATH & DISABILITY: We review the client’s cash needs at death, income needs of
surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies,
including as appropriate, living trusts, wills, review estate tax, powers of attorney,
asset protection plans, nursing homes, Medicaid and elder law.
We gather required information through in-depth personal interviews. Information
gathered includes the client’s current financial status, tax status, future goals, returns
objectives and attitudes towards risk. We carefully review documents supplied by the
client, including a questionnaire completed by the client, and prepare a written report.
Should the client choose to implement the recommendations contained in the plan, we
suggest the client work closely with his/her attorney, accountant, insurance agent, and/or
stockbroker. Implementation of financial plan recommendations is entirely at the client’s
discretion.
We also provide general non-securities advice on topics that may include tax and
budgetary planning, estate planning and business planning.
Typically, the financial plan is presented to the client within one month of the contract date,
provided that all information needed to prepare the financial plan has been promptly
provided.
Clients may engage us for a one-time consulting arrangement for an hourly fee described in
Item 5 below.
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The client is under no obligation to act upon the investment advisor’s recommendation. If
the client elects to act on any of the recommendations, the client is under no obligation to
effect the transaction through HFG.
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 objective. Clients may impose
restrictions on investing in certain securities or types of securities and we will do our best
to meet those restrictions.
Agreements may not be assigned without written client consent.
Wrap Fee Programs
HFG does not sponsor any wrap fee programs.
Client Assets Under Management
HFG has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts:
$319,109,311
$0
Date Calculated:
December 31, 2025
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
ASSET MANAGEMENT
HFG offers discretionary direct asset management services to advisory Clients for a fee of
no more than 1.25% annually. This is a flat rate fee schedule, the entire portfolio is charged
the same asset management fee. For example, a Client with $750,000 under management
would pay $9,375 on an annual basis. $750,000 x 1.25% = $9,375.
The annual fee is negotiable 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.). Fees are billed quarterly in advance based on the amount of assets managed
as of the close of business on the last business day of the previous quarter.
Lower fees for comparable services may be available from other sources. Clients may
terminate their account within five (5) business days of signing the Investment Advisory
Agreement with no obligation and without penalty. After the initial five (5) business days,
the agreement may be terminated by HFG with thirty (30) days written notice to Client and
by the Client at any time with written notice to HFG. If cash and/or securities are deposited
into or withdrawn from an existing account mid billing period a prorated fee will be
charged for that portion of the account. For accounts opened or closed mid-billing period,
fees will be prorated based on the days services are provided during the given period. All
unearned fees will be refunded to the Client. Client shall be given thirty (30) days prior
written notice of any increase in fees. Any increase in fees will be acknowledged in writing
by both parties before any increase in said fees occurs.
Accounts on the AssetMark Platform are assessed a Total Account Fee. The fees applicable
to each Account on the AssetMark Platform may include:
1. Our maximum annual fee of 1.25%,
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2. Combined Platform fee, which will now include the Custody Fee and any Strategist
or Manager Supplemental Fee, if applicable,
Other fees for special services may also be charged. The Client should consider all
applicable fees.
Client fees are payable quarterly, in advance, based on the assets under management. If
cash and/or securities are deposited into or withdrawn from an existing account mid
billing period a prorated fee will be charged for that portion of the account. The net
difference of the recalculated fees and the prior fees paid, if there are multiple such events
in the same billing period, will be combined at the next billing period and therefore may
result in a credit or debit to the account. Client may terminate AssetMark accounts at any
time and receive a full pro-rata refund on any unearned fees.
Fees and compensation for using the AssetMark Platform, are provided in more detail in
the AssetMark Platform Disclosure Brochure. Discretionary Manager Fee Schedule are
included in the Client Billing Authorization or the Appendix A to the Client Service
Agreement.
ERISA PLAN SERVICES
The annual fees are based on the market value of the Included Assets and will not exceed
1%. Fees may be charged quarterly or monthly in arrears or in advance based on the assets
as calculated by the custodian or record keeper of the Included Assets (without
adjustments for anticipated withdrawals by Plan participants or other anticipated or
scheduled transfers or distribution of assets) on the last business day of the previous
quarter or month. If the services to be provided start any time other than the first day of a
quarter or month, the fee will be prorated based on the number of days remaining in the
quarter or month. If this Agreement is terminated prior to the end of the fee period, we
shall be entitled to a prorated fee based on the number of days during the fee period
services were provided or Client will be due a prorated refund of fees for days services
were not provided in the billing cycle.
The fee schedule, which includes compensation for our services is described in detail in
Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees, however the
Plan Sponsor may elect to pay the fees. Client may elect to be billed directly or have fees
deducted from Plan Assets. We do not reasonably expect to receive any additional
compensation, directly or indirectly, for our services under this Agreement. If additional
compensation is received, we will disclose this compensation, the services rendered, and
the payer of compensation. We will offset the compensation against the fees agreed upon
under this Agreement.
FINANCIAL PLANNING AND CONSULTING
The Financial Planning Fee is determined based on the nature of the services being
provided and the complexity of each client’s circumstances. All fees are agreed upon prior
to entering into a contract with any client.
Our Financial Planning fees may be calculated and charged on a fixed fee basis, typically
ranging from $1,500 to $5,000 depending on the specific arrangement reached with the
client. Calculation of the fee is based on a $300 hourly rate.
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We may request a retainer upon completion of our initial fact-finding session with the
client; however, advance payment will never exceed $1,200 for work that will not be
completed within six months. The balance is due upon completion of the plan.
The client is billed quarterly in arrears based on actual hours accrued.
We charge an hourly fee of $300 for one-time consulting arrangements with Administrative
hours billed at $75 per hour. Although the length of time it will take to provide a Financial
Plan will depend on each client’s personal situation, we will provide an estimate for the
total hours at the start of the advisory relationship. Prior to the process the client will be
provided an estimated plan fee. The payments are received in two installments; 50% at the
commencement of the plan with the balance due within 30 days of delivery of the
recommendations. Client may cancel within five (5) business days of signing Agreement
without any obligation and without penalty. If the client cancels after five (5) business days,
any unpaid earned fees will be due to HFG or any prepaid, unearned fees will be refunded
to the client. Refunds and final invoices for partial plans will be calculated on a pro-rata
basis of worked completed based on the hourly fee stated above of $300 per hour. All
refunds will be mailed to the client’s address of record via check within 30 days of
cancellation.
Client Payment of Fees
Fees for asset management services are deducted from a designated Client account. The
Client must consent in advance to direct debiting of their investment account.
Fees for ERISA services will either be deducted from Plan assets. The Client must consent in
advance to direct debiting of their investment account.
Fees for financial plans will be billed via check – to be remitted by Client to HFG.
Additional Client Fees Charged
Custodians may charge transaction fees and other related costs on the purchases or sales of
mutual funds, equities, bonds, options and exchange-traded funds. Mutual funds, money
market funds and exchange-traded funds also charge internal management fees, which are
disclosed in the fund’s prospectus. HFG does not receive any compensation from these fees.
All of these fees are in addition to the management fee you pay to HFG. For more details on
the brokerage practices, see Item 12 of this brochure.
Prepayment of Client Fees
HFG does not require prepayment of fees of more than $1,200 per client and six months or
more in advance.
Investment management fees are billed quarterly in advance.
Fees for ERISA 3(21) and/or 3(38) services may be billed in advance.
A portion of fees for financial plans are billed in advance with the balance due upon plan
delivery.
If the Client cancels after five (5) business days, any unearned fees will be refunded to the
Client, or any unpaid earned fees will be due to HFG.
External Compensation for the Sale of Securities to Clients
Our Investment Advisor Representatives are also registered representatives of Osaic
Wealth, Inc., a full service securities broker/dealer, member FINRA/SIPC, and investment
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adviser registered with the Securities and Exchange Commission, and/or licensed as
insurance agents. In their separate capacity(ies), these individuals are able to implement
investment recommendations for advisory clients for separate and typical compensation
(i.e., commissions, 12b-1 fees or other sales-related forms of compensation). This presents
a conflict of interest to the extent that these individuals recommend that a client invest in a
security which results in a commission being paid to the individuals. Clients are not under
any obligation to engage these individuals when considering implementation of advisory
recommendations. The implementation of any or all recommendations is solely at the
discretion of the client.
Item 6: Performance-Based Fees and Side-by-Side Management
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities, but rather on a percentage of assets under management.
HFG does not use a performance-based fee structure because of the conflict of interest.
Performance based compensation may create an incentive for the advisor to recommend
an investment that may carry a higher degree of risk to the client.
Item 7: Types of Clients
Description
HFG generally provides investment advice to individuals and high net worth individuals,
trusts, estates, charitable organizations, 401(k) Plans and businesses. Client relationships
vary in scope and length of service.
Account Minimums
HFG does not require a minimum to open an account.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
HFG may utilize the following when managing client’s assets:
Fundamental analysis involves evaluating a stock using real data such as company
revenues, earnings, return on equity, and profits margins to determine underlying value
and potential growth. Technical analysis involves evaluating securities based on past prices
and volume. Cyclical analysis involves analyzing the cycles of the market. Charting analysis
involves reviewing charts of market and security activity in an attempt to identify how the
market is moving and predict how long the trend will last.
When creating a financial plan, HFG utilizes fundamental analysis to provide review of
insurance policies for economic value and income replacement. Technical analysis is used
to review mutual funds and individual stocks. The sources of information may include
Morningstar, client documents such as tax returns and insurance policies, and client
statements that include financial information.
In advising retail clients of HFG investing in the AssetMark Platform, HFG may select from
mutual funds, Exchange Traded Funds (ETF’s) and other investment solutions offered on
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the Platform. These solutions are provided by a number of institutional investment
strategists and based on the information, research, asset allocation methodology and
investment strategies of these institutional strategists, including AssetMark.
In developing a financial plan for a client, HFG’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 Securities and Exchange Commission.
Investing in securities involves risk of loss that clients should be prepared to bear. Past
performance is not a guarantee of future returns.
Investment Strategy
The investment strategy for a specific client is based upon the objectives stated by the
client during consultations. The client may change these objectives at any time by giving
notice in writing. Each client executes an Investment Policy Statement or Risk Tolerance
that documents their objectives and their desired investment strategy.
Other strategies may include long-term purchases, short-term purchases, trading, and
option writing (including covered options, uncovered options or spreading strategies).
Security Specific Material Risks
All investment programs have certain risks that are borne by the investor. Fundamental
analysis may involve interest rate risk, market risk, business risk, and financial risk. Risks
involved in technical analysis are inflation risk, reinvestment risk, and market risk. Cyclical
analysis involves inflation risk, market risk, and currency risk.
Our investment approach constantly keeps the risk of loss in mind. Investors face the
following investment risks and should discuss these risks with HFG:
•
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.
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to
tangible and intangible events and conditions. This type of risk is caused by external
factors independent of a security’s particular underlying circumstances. For
example, political, economic and social conditions may trigger market events.
•
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.
• Business Risk: These risks are associated with a particular industry or a particular
company within an industry. For example, oil-drilling companies depend on finding
oil and then refining it, a lengthy process, before they can generate a profit. They
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carry a higher risk of profitability than an electric company which generates its
income from a steady stream of customers who buy electricity no matter what the
economic environment is like.
• 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.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the
risk of profitability, because the company must meet the terms of its obligations in
good times and bad. During periods of financial stress, the inability to meet loan
obligations may result in bankruptcy and/or a declining market value.
Item 9: Disciplinary Information
Criminal or Civil Actions
The firm and its management have not been involved in any criminal or civil action
required to be reported.
Administrative Enforcement Proceedings
The firm and its management have not been involved in administrative enforcement
proceedings required to be reported.
Self-Regulatory Organization Enforcement Proceedings
The firm and its management have not been involved in legal or disciplinary events related
to past or present investment clients required to be reported.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
HFG is not registered as a broker-dealer, however affiliated representatives of ours may
also be registered representatives of an unaffiliated broker-dealer, Osaic Wealth, Inc. The
outside business activities for each investment advisory representative are disclosed in
their Form ADV Part 2B supplement to this brochure.
Futures or Commodity Registration
Neither HFG nor its employees are registered or has an application pending to register as a
futures commission merchant, commodity pool operator, or a commodity trading advisor.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
Affiliated persons of HFG are also registered representatives and investment advisor
representatives of an unaffiliated broker-dealer. From time to time they may offer client’s
products from these activities. As registered representatives and investment advisor
representatives, they may receive separate yet typical compensation in the form of
commissions and/or fees for the sale of securities products and advisory services.
Affiliated persons and employees are also independent insurance agents. From time to
time, they offer clients advice or products from this activity. They may receive separate yet
typical compensation in the form of commissions for the sale of insurance products.
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These practices represent conflicts of interest because they give an incentive to
recommend products based on the commission amount received. This conflict is mitigated
by disclosures, procedures, and the firm’s Fiduciary obligation to place the best interest of
the client first and will act according to these duties. Clients are not required to purchase
any products. Clients have the option to purchase these products through another broker-
dealer and/or insurance agent of their choosing.
Recommendations or Selections of Other Investment Advisors and Conflicts of
Interest
HFG does not select or recommend other investment advisors.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Description
The employees of HFG have committed to a Code of Ethics (“Code”). The purpose of our
Code is to set forth standards of conduct expected of HFG employees and addresses
conflicts that may arise. The Code defines acceptable behavior for employees of HFG. The
Code reflects HFG and its supervised persons’ responsibility to act in the best interest of
their client.
One area which the Code addresses is when employees buy or sell securities for their
personal accounts and how to mitigate any conflict of interest with our clients. We do not
allow any employees 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.
HFG’s policy prohibits any person from acting upon or otherwise misusing non-public or
inside information. No advisory representative or affiliate, officer or director of HFG 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.
HFG’s Code is based on the guiding principle that the interests of the client are our top
priority. HFG’s officers, directors, advisors, and other employees 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 employees or the company.
to clients, or who have access
The Code applies to “access” persons. “Access” persons are employees 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 such
recommendations that are non-public.
The firm will provide a copy of the Code of Ethics to any client or prospective client upon
request.
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest
HFG and its employees do not recommend to clients securities in which we have a material
financial interest.
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Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
HFG and its employees may buy or sell securities that are also held by clients. In order to
mitigate conflicts of interest such as front running, employees are required to disclose all
reportable securities transactions as well as provide HFG with copies of their brokerage
statements.
The Chief Compliance Officer of HFG is Kaitlin Hewell. She reviews all employee trades each
month. The personal trading reviews helps mitigate that the personal trading of employees
does not affect the markets and that clients of the firm have received preferential treatment
over employee trades.
Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
HFG does not maintain a firm proprietary trading account and does not have a material
financial interest in any securities being recommended and therefore no conflicts of
interest exist. However, employees may buy or sell securities at the same time they buy or
sell securities for clients. In order to mitigate conflicts of interest such as front running,
employees are required to disclose all reportable securities transactions as well as provide
HFG with copies of their brokerage statements.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
HFG may recommend the use of a particular broker-dealer such as Charles Schwab & Co.,
Inc. (“Schwab”). Our firm has an arrangement with Schwab Institutional division of Charles
Schwab & Co., Inc. (“Schwab”). Under the arrangement with Schwab, we receive non-soft
dollar services which include, among others; brokerage, custodial, administrative support,
record keeping and related services that are intended to support our firm in conducting
business and in serving the best interests of our clients but that may benefit our firm.
Schwab also makes certain research and brokerage services available at no additional cost
to our firm. These services include certain research and brokerage services, including
research services obtained by Schwab directly from independent research companies, as
selected by our firm (within specific parameters). Research products and services provided
by Schwab to our firm may include research reports on recommendations or other
information about, particular companies or industries; economic surveys, data and
analyses; financial publications; portfolio evaluation services; financial database software
and services; computerized news and pricing services; quotation equipment for use in
running software used in investment decision-making; and other products or services that
provide lawful and appropriate assistance by Schwab to our firm in the performance of our
investment decision-making responsibilities. The aforementioned research and brokerage
services are used by our firm to manage accounts for which we have investment discretion.
Without this arrangement, our firm might be compelled to purchase the same or similar
services at our own expense.
As a result of receiving the services discussed in 12A (1)(a) of this Firm Brochure for no
additional cost, we may have an incentive to continue to use or expand the use of Schwab
services. Our firm examined this potential conflict of interest when we chose to enter into
the relationship with Schwab and we have determined that the relationship is in the best
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interest of our firm’s clients and satisfies our client obligations, including our duty to seek
best execution.
Schwab charge brokerage commissions and transaction fees for effecting certain securities
transactions (i.e., transaction fees are charged for certain no-load mutual funds,
commissions are charged for individual equity and debt securities transactions). Schwab
enable us to obtain many no-load mutual funds without transaction charges and other no-
load funds at nominal transaction charges. Schwab and Pershing’s commission rates are
generally discounted from customary retail commission rates. However, the commission
and transaction fees charged by Schwab may be higher or lower than those charged by
other custodians and broker-dealers.
Several different third party Custodians are available on the AssetMark Platform for us by
HFG and Clients to provide Client Accounts with custody and trade services. These
Custodians include, Pershing HFG Solutions, Schwab Institutional, and Fidelity Brokerage
Services. In addition, AssetMark Trust Company (“AssetMark Trust”), an affiliate of
AssetMark, may be used by HFG and its clients on the Platform. Except as noted, HFG will
typically select the Custodian to be used.
HFG assists the client in selecting the risk/return objective and Portfolio Strategists that
best suit the client’s objectives. The client then specifically directs the account to be
invested in accordance with the chosen investment solution. When the client selects the
investment solutions, the client further directs that the account be automatically adjusted
to reflect any adjustment in the asset allocation by the selected Portfolio Strategist. This
client authorization results in the purchase and sale of certain mutual funds or ETF’s (or
transfers between variable annuity sub-accounts) without further authorization by the
client or any other party at such time as the Portfolio Strategist changes the composition of
the selected model asset allocation.
The client receives confirmations of all transactions in the account and is free to terminate
participation in the Platform and retain or dispose of any assets in the account at any time.
HFG has no authority to cause any purchase or sale of securities in any client account, or
change the selected model asset allocation or to direct the account to be invested in any
manner other than as previously authorized by the client.
• Directed Brokerage
We do not allow directed brokerage.
• Best Execution
Investment advisors who manage or supervise client portfolios on a discretionary
basis 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 effected, the ability to effect 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.
• Soft Dollar Arrangements
The Securities and Exchange Commission defines soft dollar practices as arrangement
under which products or services other than execution services are obtained by us
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from or through a broker-dealer in exchange for directing client transactions to the
broker-dealer. As permitted by Section 28(e) of the Securities Exchange Act of 1934,
we receive economic benefits as a result of commissions generated from securities
transactions by the broker-dealer from the accounts of our client. These benefits
include both proprietary research from the broker and other research written by third
parties.
A conflict of interest exists when HFG receives soft dollars. This conflict is mitigated by
disclosures, procedures, and the firm’s Fiduciary obligation to act in the best interest of
her clients and the services received are beneficial to all clients.
Aggregating Securities Transactions for Client Accounts
HFG may 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 HFG. All
clients participating in the aggregated order shall receive an average share price with all
other transaction costs shared on a pro-rated basis.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Account reviews are performed monthly by Investment Advisor Representatives of HFG.
Account reviews may be performed more frequently when market conditions dictate.
Financial plans are considered complete when the plan is delivered to the client.
Review of Client Accounts on Non-Periodic Basis
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.
Content of Client Provided Reports and Frequency
Clients receive account statements no less than quarterly for managed accounts. Account
statements are issued by the HFG’s custodian. Client receives confirmations of each
transaction in account from Custodian and an additional statement during any month in
which a transaction occurs. HFG does not provide written reports to the client.
Item 14: Client Referrals and Other Compensation
Economic benefits Provided to the Advisory Firm from External Sources and
Conflicts of Interest
Our firm may recommend that clients establish brokerage accounts with Schwab, to
maintain custody of Clients’ assets and to effect trades for their accounts. Our firm is
independently owned and operated and not affiliated with Schwab.
Our firm places trades for its Clients' accounts subject to its duty to seek best execution and
its other fiduciary duties. Our firm may use broker-dealers other than Schwab to execute
trades for client accounts maintained at Schwab, but this practice may result in additional
costs to clients so that we are more likely to place trades through Schwab rather than other
broker-dealers. Schwab and Pershing's execution quality may be different than other
broker-dealers.
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For our client accounts maintained in its custody, Schwab generally does not charge
separately for custody services but is compensated by account holders through
commissions or other transaction- related or asset-based fees for securities trades that are
executed through them or that settle into their accounts.
Some of the products, services and other benefits provided by Schwab benefit us and may
not benefit our firm's client accounts. Our recommendation/requirement that a client place
assets in Schwab’s custody may be based in part on benefits they provide to us, and not
solely on the nature, cost or quality of custody and execution services provided by them.
They also make available to our firm other products and services that benefit us but may
not benefit clients’ accounts. These benefits may include national, regional or specific to
our firm, educational events organized and/or sponsored by Schwab Institutional. Other
potential benefits may include occasional business entertainment of personnel of our firm
by Schwab Institutional, including meals, invitations to sporting events, including golf
tournaments, and other forms of entertainment, some of which may accompany
educational opportunities. Other of these products and services assist us in managing and
administering clients’ accounts. These include software and other technology (and related
technological training) that provide access to client account data (such as trade
confirmations and account statements), facilitate trade execution (and allocation of
aggregated trade orders for multiple client accounts), provide research, pricing
information and other market data, facilitate payment of our fees from its clients’ accounts,
and assist with back-office training and support functions, recordkeeping and client
reporting. Many of these services generally may be used to service all or some substantial
number of our firm’s accounts, including accounts not maintained at Schwab Institutional.
They also make available to us other services intended to help our firm manage and further
develop its business enterprise. These services may include professional compliance, legal
and business consulting, publications and conferences on practice management,
information technology, business succession, regulatory compliance, employee benefits
providers, human capital consultants, insurance and marketing. In addition, they may make
available, arrange and/or pay vendors for these types of services rendered to our firm by
independent third parties. They may discount or waive fees they would otherwise charge
for some of these services or pay all or a part of the fees of a third-party providing these
services to us. While, as a fiduciary, Our firm endeavors to act in its clients’ best interests,
our recommendation/requirement that clients maintain their assets in accounts at Schwab
may be based in part on the benefit to our firm of the availability of some of the foregoing
products and services and other arrangements and not solely on the nature, cost or quality
of custody and brokerage services provided by them, which may create a potential conflict
of interest.
From time-to-time our firm may make an error in submitting a trade order on a client’s
behalf. When this occurs, we may place a correcting trade with the broker-dealer which has
custody of the client’s account. If an investment gain results from the correcting trade, the
gain will remain in the client’s account unless the same error involved other client
account(s) that should have received the gain, it is not permissible for the client to retain
the gain, or our firm confers with the client and the client decides to forego the gain (e.g.,
due to tax reasons). If the gain does not remain in the client’s account and Schwab is the
custodian, Schwab will donate the amount of any gain $100 and over to charity. If a loss
occurs greater than $100, we will pay for the loss. Schwab will maintain the loss or gain (if
such gain is not retained in the client’s account) if it is under $100 to minimize and offset
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its administrative time and expense. Generally, if related trade errors result in both gains
and losses in the client’s account, they may be netted.
With respect to the AssetMark Platform, HFG may, subject to negotiation with AssetMark,
receive certain allowances, reimbursements or services from AssetMark in connection with
HFG’s investment advisory services to its clients, as described below and in further detail in
the Appendix 1 of the AssetMark Platform Disclosure Brochure.
for
Under AssetMark's Business Development Allowance program, HFG may receive a
reimbursement of qualified
allowance
quarterly business development
marketing/practice development expenses incurred by HFG. Those amounts vary
depending on the value of the assets on the AssetMark Platform held by Clients of HFG.
MARKETING SUPPORT FOR ADVISOR
HFG may enter into marketing arrangements with AssetMark whereby HFG receives
compensation and/or allowances in amounts based either upon a percentage of the value
of new or existing Account assets of Clients referred to AssetMark by HFG, or a flat dollar
amount.
DIRECT AND INDIRECT SUPPORT FOR ADVISOR
AssetMark may sponsor annual conferences for participating Financial Advisory Firms
and/or Financial Advisers designed to facilitate and promote the success of the Financial
Advisory Firm and/or Financial Adviser and/or AssetMark advisory services.
DISCOUNTED FEES FOR FINANCIAL ADVISORS
HFG may receive discounted pricing from AssetMark for practice management and
marketing related tools and services.
Advisory Firm Payments for Client Referrals
HFG does not compensate for client referrals.
Item 15: Custody
Account Statements
All assets are held at qualified custodians, which means the custodians provide account
statements directly to clients at their address of record at least quarterly. Clients are urged
to compare the account statements received directly from their custodians to the
performance report statements prepared by HFG.
HFG is deemed to have constructive custody solely because advisory fees are directly
deducted from client’s account by the custodian on behalf of HFG.
Item 16: Investment Discretion
Discretionary Authority for Trading
HFG accepts discretionary authority to manage securities accounts on behalf of clients. HFG
has the authority 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. The client will
authorize HFG discretionary authority
investment program
to execute selected
transactions as stated within the Investment Advisory Agreement.
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The client approves the custodian to be used and the commission rates paid to the
custodian. HFG does not receive any portion of the transaction fees or commissions paid by
the client to the custodian on certain trades.
Item 17: Voting Client Securities
Proxy Votes
HFG does not vote proxies on securities. Clients are expected to vote their own proxies. The
client will receive their proxies directly from the custodian of their account or from a
transfer agent.
Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided because HFG does not serve as a custodian
for client funds or securities and HFG does not require prepayment of fees of more than
$1200 per client and six months or more in advance.
Bankruptcy Petitions during the Past Ten Years
No bankruptcy petitions to report.
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Item 1 Cover Page
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
Kaitlin Hewell
Office Address:
8935 Ortega Road
Atascadero, CA 93422
Tel: (530) 400-4851
Web: www.hewellfinancial.com
January 29, 2026
This brochure supplement provides information about Kaitlin Hewell and supplements the Hewell
Financial Group, Inc.’s brochure. You should have received a copy of that brochure. Please contact Kaitlin
Hewell if you did not receive the brochure or if you have any questions about the contents of this
supplement.
ADDITIONAL INFORMATION ABOUT KAITLIN HEWELL (INDIVIDUAL CRD#4863224) IS AVAILABLE
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ON THE SEC’S WEBSITE AT WWW.ADVISERINFO.SEC.GOV
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer
Kaitlin (“Kate”) Hewell
• Year of birth: 1983
Item 2 Educational Background and Business Experience
Educational Background:
• University of California, Davis; Bachelor of Science in Animal Science and
Management; 2004
Business Experience:
• Hewell Financial Group, Inc.; Chief Compliance Officer/Investment Advisor
Representative; 2025 – Present
• Financial Focus LLC; Member/Investment Advisor Representative; 2015 – 02/2025
• Kaitlin Hewell – Sole Proprietor; Independent Insurance Agent; 2015 - Present
• Hewell Financial Group, Inc.; President; 2013 – Present
• Osaic Wealth, Inc.; Registered Representative; 2024 - Present
• Securities America, Inc.; Registered Representative; 2017 - 2024
• National Planning Corporation; Investment Advisor Representative/Registered
Representative; 2014 – 2017
• Hewell Financial Group, Inc.; President/Investment Advisor Representative; 2013 -
2016
• Purshe Kaplan Sterling Investments; Registered Representative; 2010 - 2014
• Laguna Financial Group, Inc.; Chief Compliance Officer/Investment Advisor
Representative; 2009 - 2013
• Linsco Private Ledger; Registered Representative; 2007 - 2010
• William Henry Crew III Wealth Management Group, Inc.; Associate Advisor; 2005 -
2007
• Ameriprise Financial; Paraplanner; 2004 - 2005
•
IDS Life Insurance Co., Insurance Agent; 2004 - 2005
Professional Certifications
Employees have earned certifications and credentials that are required to be explained in
further detail.
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame
design) marks (collectively, the “CFP® marks”) are professional certification marks granted
in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation
requires financial planners to hold CFP® certification. It is recognized in the United States
and a number of other countries for its (1) high standard of professional education; (2)
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stringent code of conduct and standards of practice; and (3) ethical requirements that
govern professional engagements with clients. Currently, more than 62,000 individuals
have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the
following requirements:
• Education – Complete an advanced college-level course of study addressing the
financial planning subject areas that CFP Board’s studies have determined as
necessary for the competent and professional delivery of financial planning services,
and attain a Bachelor’s Degree from a regionally accredited United States college or
university (or its equivalent from a foreign university). CFP Board’s financial
planning subject areas include insurance planning and risk management, employee
benefits planning, investment planning, income tax planning, retirement planning,
and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The
examination, administered in 10 hours over a two-day period, includes case studies
and client scenarios designed to test one’s ability to correctly diagnose financial
planning issues and apply one’s knowledge of financial planning to real world
circumstances;
• Experience – Complete at least three years of full-time financial planning-related
experience (or the equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of
documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and
ethics requirements in order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two
years, including two hours on the Code of Ethics and other parts of the Standards of
Professional Conduct, to maintain competence and keep up with developments in the
financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct.
The Standards prominently require that CFP® professionals provide financial
planning services at a fiduciary standard of care. This means CFP® professionals
must provide financial planning services in the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements
may be subject to CFP Board’s enforcement process, which could result in
suspension or permanent revocation of their CFP® certification.
Item 3 Disciplinary Information
Criminal or Civil Action: None to report.
Administrative Proceeding: None to report.
Self-Regulatory Organization Proceeding: None to report.
Item 4 Other Business Activities
Ms. Hewell is a registered representative with Osaic Wealth, Inc., a registered broker-dealer
and Member FINRA/SIPC. She spends 48 hours per month on this activity. Ms. Hewell is
also an independent insurance agent. Less than 10% of her time is spent on this activity.
From time to time, she offers clients advice or products from this activity. Ms. Hewell may
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receive normal and customary commissions as a result of securities and insurance
transactions and fees for advisory services.
These practices represent conflicts of interest because they give an incentive to
recommend products based on the commission amount received. This conflict is mitigated
by disclosures, procedures, and the firm’s Fiduciary obligation to place the best interest of
the clients first and clients are not required to purchase any products. Clients have the
option to purchase these products through another registered representative or insurance
agent of their choosing.
Item 5 Additional Compensation
Ms. Hewell receives commission from the sale of securities products and insurance
products but she does not receive performance based fees.
Item 6 Supervision
Since Ms. Hewell is the part owner of Hewell Financial Group, Inc., she shares responsibility
for supervision and formulation and monitoring of investment advice offered to clients. She
will adhere to the policies and procedures as described in the firm’s Compliance Manual.
Ms. Hewell can be reached at (530) 400-4851.
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