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Form ADV Part 2A
Firm Brochure
6700 Jefferson Highway, Building 4, Suite B
Baton Rouge, Louisiana, 70806
Phone: 225-778-7972
http://www.hiberniawealth.com
Effective: August 29, 2025
ITEM 1: COVER PAGE
This Form ADV Part 2A Brochure (“Brochure”) provides information about the qualifications and business
practices of Hibernia Wealth Partners, LLC. If you have any questions about the contents of this brochure, please
contact us at 225-778-7972. The information in this Brochure has not been approved or verified by the United States
Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration with the SEC does
not imply that any individual providing investment advisory services on behalf of Hibernia Wealth Partners
possesses a certain level of skill or training.
Additional information about Hibernia Wealth Partners, LLC, is also available on the SEC’s website at
www.adviserinfo.sec.gov.
Hibernia Wealth Partners
ADV Part 2A: Firm Brochure
August 2025
ITEM 2: MATERIAL CHANGES
Since this brochure was last updated on March 17, 2025, the following material changes have been made:
Item 5 has been updated to reflect a change in billing.
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Item 10 has been updated to reflect the Other Financial Industry Affiliations and Activities
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Item 11 has been updated to reflect current firm practices.
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Item 12 has been updated to reflect using Fidelity Brokerage Services LLC as a custodian.
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Item 15 has been updated to reflect current firm practices.
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ITEM 3: TABLE OF CONTENTS
ITEM 1: COVER PAGE............................................................................................................................................... I
ITEM 2: MATERIAL CHANGES .............................................................................................................................. II
ITEM 3: TABLE OF CONTENTS ............................................................................................................................. III
ITEM 4: ADVISORY SERVICES ............................................................................................................................... 4
ITEM 5: FEES AND COMPENSATION .................................................................................................................... 8
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .............................................. 11
ITEM 7: TYPES OF CLIENTS .................................................................................................................................. 11
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS .............................. 11
ITEM 9: DISCIPLINARY INFORMATION ............................................................................................................. 16
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............................................... 16
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND
PERSONAL TRADING ............................................................................................................................................. 17
ITEM 12: BROKERAGE PRACTICES ..................................................................................................................... 18
ITEM 13: REVIEW OF ACCOUNTS ........................................................................................................................ 21
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ...................................................................... 22
ITEM 15: CUSTODY ................................................................................................................................................. 23
ITEM 16: INVESTMENT DISCRETION .................................................................................................................. 23
ITEM 17: VOTING CLIENT SECURITIES .............................................................................................................. 24
ITEM 18: FINANCIAL INFORMATION .................................................................................................................. 24
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ITEM 4: ADVISORY SERVICES
Hibernia Wealth Partners, LLC (“HWP,” the “Adviser” or the “Firm”) is a U.S. Securities & Exchange
Commission (“SEC”) registered investment adviser and is a privately held limited liability company
organized under the laws of Louisiana. HWP was approved for registration by the SEC on May 5, 2022.
Paul V. Saltaformaggio is the founder, owner, managing member, and Chief Compliance Officer (“CCO”)
of HWP. The Adviser and its operations are solely under his control.
HWP manages assets on a discretionary basis and non-discretionary basis. As of 12/31/2024, the total
amount of discretionary assets under management was $ 346,617,660 , and zero non-discretionary assets
under management.
Types of Advisory Services
INVESTMENT ADVISORY SERVICES
HWP offers investment advisory/asset management services to advisory Clients. HWP will offer Clients
ongoing 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.
Discretionary
When the Client elects to use HWP on a discretionary basis, the Client will sign a limited trading
authorization or equivalent allowing HWP to determine the securities to be bought or sold and the
amount of the securities to be bought or sold. HWP will have the authority to execute transactions
in the account without seeking Client approval on each transaction.
Non-Discretionary
When the Client elects to use HWP on a non-discretionary basis, HWP will determine the securities
to be bought or sold and the amount of the securities to be bought or sold. However, HWP will
obtain prior Client approval on each and every transaction before executing any transaction.
HWP may also select and appoint one or more Sub-Advisor(s) to provide Sub-Advisor Services to Client’s
Account. Such Sub-Advisor Services will be as determined by HWP. Such Sub-Advisor(s), in providing
Sub-Advisor Services, shall have all of the same authority relating to the management, including fee
deduction authority, of Client’s Account as is granted to HWP. In addition, at HWP’s discretion, HWP may
grant such Sub-Advisor(s) full authority to further delegate such discretionary investment authority to other
Money Managers. Client will agree to such authority within HWP’s Advisory Agreement.
Third-Party Management
When deemed appropriate for the Client, HWP may recommend that Clients utilize the services of a Third-
Party Manager (TPM) to manage a portion of, or all of the Client’s portfolio. All TPMs that HWP
recommends must be Registered Investment Advisors with the SEC or with the appropriate state
authority(ies).
After gathering information about your financial situation and objectives, an investment advisor
representative of our firm will make recommendations regarding the suitability of a TPM or investment
style based on, but not limited to, your financial needs, investment goals, tolerance for risk, and investment
objectives. Upon selection of a TPM(s), we will monitor the performance of the TPM(s) to ensure their
performance and investment style remain aligned with your investment goals and objectives.
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In such circumstances, HWP receives solicitor fees from the TPM. We act as the liaison between the Client
and the TPM in return for an ongoing portion of the advisory fees charged by the TPM. We help the Client
complete the necessary paperwork of the TPM and provide ongoing services to the Client. Ongoing services
include but are not limited to:
• Provide information to each Client concerning the investment advisor services offered by
TPM and the fee schedule of such services.
• Deliver the Form ADV Part 2, Privacy Notice, Form CRS, and Disclosure Statement to the
Client, as applicable.
• Meet with the Client to discuss any changes in status, objectives, time horizon or suitability.
• Update the TPM with any changes in Client status which is provided to HWP by the Client.
Clients placed with TPM will be billed in accordance with the TPM’s Fee Schedule which will be disclosed
to the Client prior to signing an agreement.
FINANCIAL PLANNING AND CONSULTING
Financial planning services include an evaluation of a Client's current and future financial state and will be
provided by using currently known variables to predict future cash flows, asset values and withdrawal plans.
HWP will use current net worth, tax liabilities, asset allocation, and future retirement and estate plans in
developing financial plans. Topics generally reviewed in a financial plan may include but are not limited
to:
• Personal net worth statement: A snapshot of assets and liabilities serves as a benchmark
for measuring progress towards financial goals.
• Cash flow analysis: An income and spending plan determines how much can be set aside
for debt repayment, savings and investing each month.
• Retirement strategy: A strategy for achieving retirement independent of other financial
priorities. Including a strategy for accumulating the required retirement capital and its
planned lifetime distribution.
• Long-term investment plan: Build a customized asset allocation strategy based on specific
investment objectives and a risk profile. This strategy sets guidelines for selecting, buying,
and selling investments and establishing benchmarks for performance review.
• Tax reduction strategy: Identify ways to minimize taxes on personal income to the extent
permissible by the tax code. The strategy should include identification of tax favored
investment vehicles that can reduce taxation of investment income.
• Estate preservation: Help update accounts, review beneficiaries for retirement accounts
and life insurance, provide a second look at your current estate planning documents, and
prompt you to update your plan when the legal environment changes or you have major life
events such as a marriage, death, or births.
If a conflict of interest exists between the interests of HWP and the interests of the Client, the Client is
under no obligation to act upon HWP’s recommendation. If the Client elects to act on any of the
recommendations, the Client is under no obligation to affect the transaction through HWP. Financial plans
will be completed and delivered within six months contingent upon timely delivery of all required
documentation.
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ERISA PLAN SERVICES
HWP offers service to qualified and non-qualified retirement plans including 401(k) plans, 403(b) plans,
pension and profit-sharing plans, cash balance plans, and deferred compensation plans. HWP may act as a
3(21):
Limited Scope ERISA 3(21) Fiduciary. HWP acts as a limited scope ERISA 3(21) fiduciary that can
advise, help, and assist plan sponsors with their investment decisions. As an investment advisor
HWP has 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 HWP can help the plan sponsor
delegate liability by following a diligent process.
1. Fiduciary Services are:
• Provide 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.
Clients will make the final decision regarding the initial selection, retention, removal, and
addition of investment options. HWP acknowledges that it is a fiduciary as defined in ERISA
section 3(21)(A)(ii).
• 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 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 of providing 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 the 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 with general investment information and the
investment alternatives available to them under the Plan. Client understands HWP’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, HWP is not providing fiduciary advice as defined by
ERISA 3(21)(A)(ii) to the Plan participants. HWP 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.
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HWP may provide these services or, alternatively, may arrange for the Plan’s other providers to
offer these services, as agreed upon between HWP and Client.
3. HWP 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 the calculation of Fees paid to HWP on the ERISA Agreement.
Specific services will be outlined in detail for each plan in the 408(b)2 disclosure.
Client accounts held at a custodian that is not directly accessible by HWP, such as defined contribution plan
participant accounts (held away accounts), may be managed using the Pontera Order Management System
(“Pontera”) or a similar platform. The platform allows HWP to avoid being considered to have custody of
client funds since HWP does not have direct access to client log-in credentials to affect trades. HWP is not
affiliated with the platform in any way and receives no compensation from them for using their platform.
A link will be provided to the Client allowing them to connect an account(s) to the platform. Once a Client
account(s) is connected to the platform, HWP will review the current account allocations. When deemed
necessary, HWP will rebalance the account considering client investment goals and risk tolerance, and any
change in allocations will consider current economic and market trends.
The goals and objectives for each Client are documented in our Client files. Investment strategies are created
that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities
or types of securities. These restrictions may, however, prohibit engagement with HWP.
WRAP FEE PROGRAM
HWP offers Wrap-Fee Program to simplify the payment of management fees and brokerage expenses. The
wrap fee includes the brokerage expenses (i.e., commissions, ticket charges, etc.) of the account as well as
our management fee. For further details, please see Hibernia Wealth Partners, LLC ADV Form 2A,
Appendix 1, Wrap Fee Program Brochure. Wrap Fee and Non-Wrap Fee accounts are managed on an
individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc. As
further described in the Hibernia Wealth Partners, LLC ADV Form 2A, Appendix 1, Wrap Fee Program
Brochure, HWP receives a portion of the Wrap Fee for services provided.
The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated
with managing the account, and the frequency or type of securities transactions executed in the account.
For example, a wrap fee program may not be suitable for all accounts, including but not limited to accounts
holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income
securities or no-transaction-fee mutual funds, or any other type of security that can be traded without
commissions or other transaction fees.
In order to evaluate whether a wrap (or bundled) fee arrangement is appropriate for you, you should compare
the agreed-upon Wrap Program Fee and any other costs associated with participating in our Wrap Fee
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Program with the amounts that would be charged by other advisers, broker-dealers, and custodians, for
advisory fees, brokerage and execution costs, and custodial services comparable to those provided under
the Wrap Fee Program.
ITEM 5: FEES AND COMPENSATION
FEE SCHEDULES
INVESTMENT ADVISORY SERVICES
Advisory fees are negotiable, may be asset-based or fixed fees, and vary by client. Asset-based fees range
from 0-3% annually based on a multiple of factors including the complexity of services provided, the level
of assets to be managed, family relationships, and the overall relationship with HWP. The exact fee for
services will be agreed upon and listed in the Investment Advisory Agreement prior to services being
provided.
Advisory fees are deducted from your account by the qualified custodian. HWP facilitates the billing
process. Clients must consent in advance to the direct debiting of your fees from the account by signing the
Investment Advisory Agreement. Custodians deliver account statements directly to clients at least quarterly.
Account statements show all disbursements from client account(s). Clients are encouraged to review your
account statements for accuracy.
When purchasing securities and investment products away from HWP, partial withdrawals or additional
deposits may result in a prorated refund or credit of fees to your account(s). Fee adjustments for partial
withdrawals and additional deposits may be calculated in arrears on the next quarterly period billing cycle.
Fee adjustments will be calculated based on the value at the time of the additional deposit or partial
withdrawal.
All client accounts asset-based fees are billed quarterly per account and paid in advance. The Firm calculates
advisory fees based on the account’s quarter-end value. Inflows and outflows during the billing period are
not prorated unless they exceed a materiality threshold. Specifically, any deposits or withdrawals that are
less than 5% of the account’s billable value will not result in an adjustment to the advisory fee.
This approach is designed to streamline billing and reduce administrative burden while maintaining fairness
and transparency. The Firm believes this threshold-based method provides a reasonable balance between
accuracy and efficiency.
Clients are encouraged to contact the Firm with any questions regarding how their fees are calculated.
Terminated accounts are entitled to a prorated refund of any pre-paid quarterly fee based upon the number
of days remaining in the billing quarter. The account value includes cash but excludes restricted or self-
directed assets.
For any client relationship with fixed fees, the applicable amount is billed quarterly in advance. The fee
charged is one-quarter of the annual fee. For accounts terminated prior to the end of any given quarter, fees
will be calculated based on actual number of days in the quarter when the account was under HWP
management.
THIRD PARTY MANAGEMENT
For Third-Party Manager (TPM), clients pay an advisory fee as set out in the client agreement with the
TPM sponsor. For some arrangements where a TPM will be used, that advisory fee is set by the TPM. In
other arrangements, that fee is negotiated among the TPM and HWP. Fees may be different from one TPM
to another. Further, fees are not commensurate with education or experience. The TPM sponsor may
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establish a fee schedule or set a minimum or maximum fee. The TPM fee schedule will be set out in the
Disclosure Brochure provided by the TPM sponsor. The advisory fee typically is based on the value of
assets under management as valued by the custodian of the assets for the account and will vary by program.
The advisory fee typically will be deducted from the account by the custodian and paid quarterly in arrears
or in advance. The advisory fee is often paid to the TPM sponsor, who in turn pays a portion to HWP. A
TPM account may be terminated by a party pursuant to the terms outlined in the TPM client agreement. The
TPM client agreement will explain how clients can obtain a refund of any pre-paid fee if the agreement is
terminated before the end of a billing period.
FINANCIAL PLANNING AND CONSULTING
HWP charges an hourly, ongoing, and/or fixed fee for financial planning and consulting. Prior to the
planning process the Client will be provided an estimated plan fee which will be based on the complexity
of the engagement. For hourly and fixed fee arrangements, services will be completed and delivered within
six months contingent upon timely delivery of all required documentation. HWP reserves the right to waive
the fee should the Client implement the plan through HWP.
HOURLY FEES
Hourly Fee Services are offered based on an hourly fee of $500 per hour. Hourly fees for financial
plans are billed 50% in advance with the balance due upon plan delivery. Hourly fees are based on
initial estimates of hours required to create and deliver the plan and billed based on actual time used
to complete the plan.
FIXED FEES
Fixed Fee Services are offered with prices ranges depending on the complexity of the engagement.
Fees are billed 50% in advance with the balance due upon plan delivery or paid in full upfront.
ONGOING FEES
Ongoing Fee Services are offered based on an annual fee and charged either monthly or quarterly
depending on the Client’s election. Fees are billed in advance of each billing period. Ongoing Fee
Services will continue year over year until canceled, in writing, by either HWP or the Client.
Clients may terminate, with written notice to HWP, planning and/or consulting advisory services within
five business days after entering into the advisory agreement, without penalty or obligation and for a full
refund of any prepaid fees. After five business days of entering into the financial planning advisory
agreement, clients may terminate upon WHP’s receipt of a client’s written notice to terminate. If fees have
been prepaid and a financial planning engagement is terminated prior to completion, the client will be
entitled to a refund of unearned fees. After the completion and presentation of the services, no refunds will
be issued.
ERISA PLAN SERVICES
The annual fees are based on the market value of the Included Assets and shall 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.
The fee schedule, which includes compensation of HWP for the services is described in detail in the ERISA
Plan Agreement. The Plan is obligated to pay the fees; however, the Plan Sponsor may elect to pay the fees.
Clients may elect to be billed directly or have fees deducted from Plan Assets. HWP does not reasonably
expect to receive any additional compensation, directly or indirectly, for its services. If additional
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compensation is received, HWP will disclose this compensation, the services rendered, and the payer of
compensation.
PAYMENT OF FEES
Investment Advisory Fees are deducted directly from the Client’s Account.
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• For TPM services, the method of payment will be disclosed in the TPM’s Form ADV Part 2.
• Financial Planning and Consulting Fees are generally invoiced directly to the Client. Clients pay via
AdvicePay or by check.
• ERISA Fees are deducted directly from the Client’s Account.
HWP, in its sole discretion, may charge a lesser investment advisory fee based upon certain criteria (e.g.,
historical relationship, type of assets, anticipated future earning capacity, anticipated future additional
assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with
Clients, etc.).
For all services, Clients may terminate their engagement with HWP within five (5) business days of signing
an Agreement with no obligation and without penalty. After the initial (5) business days, the Agreement
may be terminated by HWP with thirty (30) days written notice to Client and by the Client at any time with
written notice to HWP. For accounts opened or closed mid-billing period, fees will be prorated based on
the days services are provided during the given period. In the case of hourly engagements, fees will be
prorated based on the work completed at the stated hourly rate. All unpaid earned fees will be due to HWP,
and all unearned fees will be refunded to the Client. Any increase in fees will be acknowledged in writing
by both parties before any increase in said fees occurs.
Additional Fees
Custodians may charge brokerage commissions, transaction fees, and other related costs on the purchases
or sales of mutual funds, equities, bonds, options, margin interest, and exchange-traded funds. Mutual funds,
money market funds, and exchange-traded funds may also charge internal management fees, which are
disclosed in the fund’s prospectus. HWP does not receive any compensation from these fees. All of these
fees are in addition to the management fee you pay to HWP. For more details on the brokerage practices,
see Item 12 of this brochure.
External Compensation for the Sale of Securities
Certain IARs of HWP are also associated with LPL Financial as broker-dealer registered representatives
(“dually registered persons”). In their capacity as registered representatives of LPL, certain dually registered
persons may earn commissions for the sale of securities or investment products that they recommend for
brokerage clients. They do not earn commissions on the sale of securities or investment products
recommended or purchased in advisory accounts through HWP. Clients have the option of purchasing many
of the securities and investment products we make available to you through another broker-dealer or
investment adviser. However, when purchasing these securities and investment products away from HWP,
you will not receive the benefit of the advice and other services we provide.
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IITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
HWP does not charge performance fees. HWP does not engage in Side-By-Side Management.
ITEM 7: TYPES OF CLIENTS
HWP provides investment advisory services to individuals, high-net-worth individuals, trusts, corporations,
retirement and pension plans, and other institutional investors. HWP does not require a minimum asset
amount for financial planning or hourly consulting.
For TPMs, the TPM sponsor typically establishes a minimum account value, which will be set out in the
account opening documents with the TPM sponsor.
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF
LOSS
Methods of Analysis and Investment Strategies
Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not
a guarantee of future returns. Security analysis methods may include:
Fundamental analysis concentrates on factors that determine a company’s value and expected future
earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced
below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived
value.
Technical analysis attempts to predict a future stock price or direction based on market trends. The
assumption is that the market follows discernible patterns and if these patterns can be identified then a
prediction can be made. The risk is that markets do not always follow patterns and relying solely on this
method may not take into account new patterns that emerge over time.
Charting analysis strategy involves using and comparing various charts to predict long and short-term
performance or market trends. The risk involved in using this method is that only past performance data is
considered without using other methods to crosscheck data. Using charting analysis without other methods
of analysis would be making the assumption that past performance will be indicative of future performance.
This may not be the case.
Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged
to provide performance. The risks with this strategy are twofold: 1) the markets do not always repeat cyclical
patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these
investors are trying to exploit.
Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such
as the character of management or the state of employee morale, such as the value of assets, the cost of
capital, historical projections of sales, and so on.
Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a
given amount of portfolio risk or equivalently minimize risk for a given level of expected return, each by
carefully choosing the proportions of various assets.
In developing a financial plan for a Client, HWP’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.
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The main sources of information include financial newspapers and magazines, annual reports, prospectuses,
and filings with the SEC.
TPMs utilized by HWP may use various methods of analysis to determine the proper strategy for the Client
referred and these will be disclosed in the TPM’s Form ADV Part 2. Investing in securities involves risk of
loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Other
strategies utilized by TPMs may include long-term purchases, short-term purchases, trading, and option
writing (including covered options, uncovered options, or spreading strategies).
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 providing written notice to HWP.
Each Client executes a Client profile form or similar form that documents their objectives and their desired
investment strategy.
Risks of Investments and Strategies Utilized
Investing in securities involves risk of loss that Clients should be prepared to bear. HWP’s investment
approach constantly keeps the risk of loss in mind. Investors may face the following investment risks:
General Investment and Trading Risks. Clients may invest in securities and other financial instruments
using strategies and investment techniques with significant risk characteristics. The investment program
utilizes such investment techniques as option transactions, margin transactions, short sales, leverage, and
derivatives trading, the use of which can, in certain circumstances, maximize the adverse impact to which
a Client may be subject.
Interest-rate Risk. Fluctuations in interest rates may cause investment prices to fluctuate. For example,
when interest rates rise, yields on existing bonds become less attractive, causing their market values to
decline.
Inflation Risk. When any type of inflation is present, a dollar today will buy more than a dollar next year,
because purchasing power is eroding at the rate of inflation.
Currency Risk. Overseas investments are subject to fluctuations in the value of the dollar against the
currency of the investment’s originating country. This is also referred to as exchange rate risk.
Reinvestment Risk. This is the risk that future proceeds from investments may have to be reinvested at a
potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities.
Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. Generally, assets are
more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly
liquid, while real estate properties are not.
Management Risk. The advisor’s investment approach may fail to produce the intended results. If the
advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the
expected time frame, the overall performance of the Client’s portfolio may suffer.
Cybersecurity Risk. HWP and its service providers may be subject to operational and information security
risks resulting from cyberattacks. Cyberattacks include, among other behaviors, stealing or corrupting data
maintained online or digitally, denial of service attacks on websites, the unauthorized release of confidential
information or various other forms of cybersecurity breaches. Cybersecurity attacks affecting HWP, and its
service providers may adversely impact Clients. For instance, cyberattacks may interfere with the
processing of transactions, cause the release of private information about Clients, impede trading, subject
HWP to regulatory fines or financial losses, and cause reputational damage. Similar types of cybersecurity
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risks are also present for issuers of securities in which Clients may invest in, qualified custodians,
governmental and other regulatory authorities, exchange and other financial market operators, or other
financial institutions. Cybersecurity incidents that could ultimately cause them to incur losses, including for
example: financial losses, cost and reputational damages, and loss from damage or interruption of systems.
Although HWP has established its systems to reduce the risk of these incidents from coming to fruition,
there is no guarantee that these efforts will always be successful, especially considering that HWP does not
directly control the cybersecurity measures and policies employed by third party service providers.
Options Trading. The risks involved with trading options are that they are very time-sensitive investments.
An options contract is generally for a few months. The buyer of an option could lose his or her entire
investment even with a correct prediction about the direction and magnitude of a particular price change if
the price change does not occur in the relevant time period (i.e., before the option expires). Additionally,
options are less tangible than some other investments. An option is a “book-entry” only investment without
a paper certificate of ownership.
Trading on Margin. In a cash account, the risk is limited to the amount of money that has been invested.
In a margin account, risk includes the amount of money invested plus the amount that has been loaned. As
market conditions fluctuate, the value of marginable securities will also fluctuate, causing a change in the
overall account balance and debt ratio. As a result, if the value of the securities held in a margin account
depreciates, the Client will be required to deposit additional cash or make full payment of the margin loan
to bring the account back up to maintenance levels. Clients who cannot comply with such a margin call
may be sold out or bought in by the brokerage firm.
Exchange-Traded Funds. ETFs are a type of index fund bought and sold on a securities exchange. The
risks of owning an ETF generally reflect the risks of owning the underlying securities they are designed to
track, although lack of liquidity in an ETF could result in it being more volatile and ETFs have management
fees that increase their costs. ETFs are also subject to other risks, including: (i) the risk that their prices may
not correlate perfectly with changes in the underlying reference units; and (ii) the risk of possible trading
halts due to market conditions or other reasons that, in the view of the exchange upon which an ETF trades,
would make trading in the ETF inadvisable.
Mutual Fund Risks. An investment in mutual funds could lose money over short or even long periods. A
mutual fund’s share price and total return are expected to fluctuate within a wide range, like the fluctuations
of the overall stock market.
Common Stocks and Equity-Related Securities. Certain ETFs or mutual funds hold common stock.
Prices of common stock react to the economic condition of the company that issued the security, industry
and market conditions, and other factors which may fluctuate widely. Investments related to the value of
stocks may rise and fall based on an issuer’s actual and anticipated earnings, changes in management, the
potential for takeovers and acquisitions, and other economic factors. Similarly, the value of other equity-
related securities, including preferred stock, warrants, and options may also vary widely.
Small- and Mid-Cap Risks. Certain ETFs and mutual funds hold securities of small- and mid-cap issuers.
Securities of small-cap issuers may present greater risks than those of large-cap issuers. For example, some
small- and mid-cap issuers often have limited product lines, markets, or financial resources. They may be
subject to high volatility in revenues, expenses, and earnings. Their securities may be thinly traded, may be
followed by fewer investment research analysts, and may be subject to wider price swings and thus may
create a greater chance of loss than when investing in securities of larger-cap issuers. The market prices of
securities of small- and mid-cap issuers generally are more sensitive to changes in earnings expectations,
to corporate developments, and to market rumors than are the market prices of large-cap issuers.
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Futures, Commodities, and Derivative Investments. Certain ETFs and mutual funds hold commodities,
commodities contracts, and/or derivative instruments, including futures, options, and swap agreements. The
prices of commodities contracts and derivative instruments, including futures and options, are highly
volatile. Payments made pursuant to swap agreements may also be highly volatile. Price movements of
commodities, futures and options contracts, and payments pursuant to swap agreements are influenced by,
among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and
exchange control programs and policies of governments, and national and international political and
economic events and policies. The value of futures, options, and swap agreements also depends upon the
price of the commodities underlying them. In addition, Client assets are subject to the risk of the failure of
any of the exchanges on which its positions trade or of its clearinghouses or counterparties.
Highly Volatile Markets. The prices of financial instruments can be highly volatile. Price movements of
forward and other derivative contracts are influenced by, among other things, interest rates, changing supply
and demand relationships, trade, fiscal, monetary and exchange control programs and policies of
governments, and national and international political and economic events and policies. Clients are also
subject to the risk of failure of any of the exchanges on which their positions trade or of their clearinghouses.
Non-U.S. Securities. Certain ETFs and mutual funds hold securities of non-U.S. issuers. Investments in
securities of non-U.S. issuers pose a range of potential risks which could include expropriation, confiscatory
taxation, imposition of withholding or other taxes on dividends, interest, capital gains or other income,
political or social instability, illiquidity, price volatility, and market manipulation. In addition, less
information may be available regarding securities of non-U.S. issuers, and non-U.S. issuers may not be
subject to accounting, auditing and financial reporting standards, and requirements comparable to or as
uniform as those of U.S. issuers.
Emerging Markets. Certain ETFs and mutual funds hold securities of emerging markets issuers. In
addition to the risks associated with investments outside of the United States, investments in emerging
markets (i.e., the developing countries) may involve additional risks. Emerging markets generally are not
as efficient as those in developed countries. In some cases, a market for the security may not exist locally,
and transactions will need to be made on a neighboring exchange. Volume and liquidity levels in emerging
markets are lower than in developed countries. When seeking to sell emerging market securities, little or
no market may exist for the securities. In addition, issuers based in emerging markets are not generally
subject to uniform accounting and financial reporting standards, practices, and requirements comparable to
those applicable to issuers based in developed countries, thereby potentially increasing the risk of fraud or
other deceptive practices.
Capitalization Risks. Investing in Companies within the same market capitalization category carries the
risk that the category may be out of favor due to current market conditions or investor sentiment.
Market Risks. Turbulence in the financial markets and reduced liquidity may negatively affect the
Companies, which could have an adverse effect on each of them. If the securities of the Companies
experience poor liquidity, investors may be unable to transact at advantageous times or prices, which may
decrease the Company’s returns. In addition, there is a risk that policy changes by central governments and
governmental agencies, including the Federal Reserve or the European Central Bank, which could include
increasing interest rates, could cause increased volatility in financial markets, which could have a negative
impact on the Companies. Furthermore, local, regional, or global events such as war, acts of terrorism, the
spread of infectious illness or other public health issues, recessions, or other events could have a significant
impact on the Companies. For example, the rapid and global spread of a highly contagious novel
coronavirus respiratory disease, designated COVID-19, has resulted in extreme volatility in the financial
markets and severe losses; reduced liquidity of many Companies’ securities; restrictions on international
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and, in some cases, local travel; significant disruptions to business operations (including business closures);
strained healthcare systems; disruptions to supply chains, consumer demand and employee availability; and
widespread uncertainty regarding the duration and long-term effects of this pandemic. Some sectors of the
economy and individual issuers have experienced particularly large losses. In addition, the COVID-19
pandemic may result in a sustained economic downturn or a global recession, domestic and foreign political
and social instability, damage to diplomatic and international trade relations and increased volatility and/or
decreased liquidity in the securities markets. The Companies’ values could decline over short periods due
to short-term market movements and over longer periods during market downturns.
Inverse and Leveraged Products. HWP may recommend and engage in trading with leveraged and inverse
products. These products are aggressive in nature and carry unusual and significant risk. They are not
appropriate for inexperienced investors. These products are intended to be used/traded daily. Most
leveraged and inverse ETFs reset on a daily basis and have published prospectuses that state (I) they’re
designed to achieve their stated objective within one day, (2) clients can lose all of their investment
potentially in one day, and (3) holding these securities for periods longer than one day could lead to losses
even if the underlying index moves in the anticipated direction. Regulatory organizations, such as FINRA
& SEC, have released alerts stating that inverse and leveraged ETFs that reset daily typically are not suitable
for retail investors who plan to hold them longer than one day. Managers may hold these products in client
accounts for periods of time significantly greater than one day. Investors with holding periods longer than
a day expose themselves to substantial risk as the holding period returns will deviate from the returns to a
leveraged or inverse investment in the index. It is possible for an investor in a leveraged ETF to experience
negative returns even when the underlying index has positive returns.
Penny Stock Risks. Generally, Penny Stocks are low-priced shares of small companies that do not trade
on an exchange. Penny Stocks typically trade over the counter, such as on the OTC Bulletin Board or Pink
Sheets. Penny Stocks, unlike listed stocks, are not subject to SEC reporting requirements or the listing
standards of stock exchanges. Because of this, information about the Penny Stock companies can be difficult
to find and verify. Penny Stocks also have lower liquidity as they trade less frequently. This also leads to
higher volatility. For these reasons, Penny Stocks are considered to be speculative investments and Clients
who trade in penny stocks should be prepared for the possibility that they may lose their entire investment,
or an amount in excess of their investment if they purchase Penny Stocks on margin.
Variable Annuity Risk. A variable annuity is a form of insurance where the seller or issuer (typically an
insurance company) makes a series of future payments to a buyer (annuitant) in exchange for the immediate
payment of a lump sum (single-payment annuity) or a series of regular payments (regular-payment annuity).
The payment stream from the issuer to the annuitant has an unknown duration based principally upon the
date of death of the annuitant. At this point, the contract will terminate, and the remainder of the funds
accumulated are forfeited unless there are other annuitants or beneficiaries in the contract. Annuities can be
purchased to provide an income during retirement. Unlike fixed annuities that make payments in fixed
amounts or in amounts that increase by a fixed percentage, variable annuities pay amounts that vary
according to the performance of a specified set of investments, typically bond and equity mutual funds.
Many variable annuities typically impose asset-based sales charges or surrender charges for withdrawals
within a specified period. Variable annuities may impose a variety of fees and expenses, in addition to sales
and surrender charges, such as mortality and expense risk charges; administrative fees; underlying fund
expenses; and charges for special features, all of which can reduce the return. Earnings in a variable annuity
do not provide all the tax advantages of 401(k)s and other before-tax retirement plans. Once the investor
starts withdrawing money from their variable annuity, earnings are taxed at the ordinary income rate, rather
than at the lower capital gains rates applied to other non-tax-deferred vehicles which are held for more than
one year. Proceeds of most variable annuities do not receive a “step-up” in cost basis when the owner dies
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like stocks, bonds and mutual funds do. Some variable annuities offer “bonus credits.” These are usually
not free. In order to fund them, insurance companies typically impose mortality and expense charges and
surrender charge periods. In an exchange of an existing annuity for a new annuity (so-called 1035
exchanges), the new variable annuity may have a lower contract value and a smaller death benefit; may
impose new surrender charges or increase the period of time for which the surrender charge applies; may
have higher annual fees; and provide another commission for the broker.
Alternative Investments. When appropriate for a Client’s objective, risk tolerance and qualifications,
HWP recommends the client participate in private issues, such as single purpose vehicles, funds of funds,
private equity, and hedge funds. These are usually structured as limited partnerships with differing
minimum investments, liquidity, fees and carriers.
The foregoing list of risk factors does not purport to be a complete enumeration or explanation of the
risks involved in an investment with HWP.
ITEM 9: DISCIPLINARY INFORMATION
HWP and its management have not been involved in any criminal or civil actions, administrative or self-
regulatory enforcement proceedings, nor any legal or disciplinary events that are material to a Client’s or
prospective Client’s evaluation of HWP or the integrity of its management.
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Registered Representatives of a Broker Dealer
Most HWP IARs are Dually Registered Persons by being an IAR with HWP and a registered representative
(“RR”) with LPL Financial. LPL Financial is a broker-dealer that is independently owned and operated and
is not affiliated with HWP. Please refer to Item 12 for a discussion of the benefits HWP may receive from
LPL Financial and the conflicts of interest associated with receipt of such benefits. Clients may maintain
multiple accounts with an IAR, some of which are subject to an investment advisory relationship through
HWP, while others may operate under a brokerage relationship through LPL. Clients are under no obligation
to purchase or sell securities through IARs. However, if a client chooses to implement the
recommendations, commissions may be earned by IARs as RRs of LPL for brokerage transactions in
addition to any fees paid for advisory services. Commissions may be higher or lower at LPL than at other
broker/dealers.
IARs have a conflict of interest by having clients purchase securities and/or insurance related products
through LPL in that the higher their production with LPL the greater potential for obtaining a higher pay-
out on commissions earned. Further, IARs may be restricted to only offering those products and services
that have been reviewed and approved for offering to the public through LPL. The amount of time spent by
each IAR offering securities products on a commission basis as a RR of LPL will vary. Some IARs may
spend significantly more or less time offering commissionable products and services through LPL.
As discussed previously, certain associated persons of HWP are RRs of LPL Financial. As a result of this
relationship, LPL may have access to certain confidential information (e.g., financial information,
investment objectives, transactions, and holdings) about HWP’s clients, even if the client does not establish
an account through LPL Financial. If you would like a copy of the LPL Financial Privacy Policy, please
contact our Chief Compliance Officer at 225-778-7972.
IARs are generally independent contractors of HWP, and the experience, level of education, level and/or
sophistication of services, and fees will vary. Fees may not be commensurate with education and/or
experience. However, the fees clients will pay for the advisory services described herein will not exceed
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the stated fee schedules. Further, clients are advised that they may pay more or less for similar services
received by another client serviced by another IAR.
Insurance Agents
HWP IARs registered with LPL may offer insurance products and services for which commissions will be
paid. IARs and other related persons of HWP (defined as any advisory affiliate and any person that is under
common control with HWP) may be licensed with various insurance companies. HWP, its IARs and related
persons have a conflict of interest when recommending clients purchase insurance products, as commissions
may be earned in addition to fees for advisory services. Clients are not obligated to purchase insurance
products through HWP or its IARs. Some IARs may spend significantly more or less time offering
insurance products and services. The principal business of HWP is not to offer insurance products and
services. Less than 10% of HWP’s resources are dedicated to insurance business.
Affiliation with Hibernia Wealth Management.
HWP is under common ownership with Hibernia Wealth Management (HWM). an investment advisory
firm. HWM provides asset management, financial planning and financial consulting services to retail
clients. HWP and HWM will share office space and operational personnel.
IAR’s may have their own legal business entities whose trade names and logos are used for marketing
purposes and may appear on marketing materials and/or client statements. The client should understand that
the businesses are legal entities of the IAR and not of HWP. The IARs are under the supervision of HWP,
and the advisory services of the IAR are provided through HWP. HWP has these arrangements with the
business entities listed in Schedule D of Form ADV.
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS, AND PERSONAL TRADING
Code of Ethics and Personal Trading
As an investment adviser registered with the SEC, HWP has a fiduciary obligation to clients to act in the
best interest of its clients at all times and to always place the client’s interests first and foremost. HWP takes
its compliance and regulatory obligations seriously and requires all staff to comply with such rules and
regulations, as well as HWP’s policies and procedures. In accordance with this goal, HWP strives to handle
clients’ non-public information in a manner intended to prevent it from falling into hands that have no
business reason to know such information. A copy of the HWP Privacy Notice is provided to clients. In
addition, HWP maintains a Code of Ethics for its IARs, supervised persons, and staff.
The Code of Ethics contains provisions for standards of business conduct designed to help ensure
compliance with federal securities laws, personal securities reporting requirements, pre-approval
procedures for certain transactions, code violations reporting requirements, and safeguarding of material
non-public information about client transactions. Further, HWP’s Code of Ethics establishes HWP’s
expectations for business conduct.
HWP’s Code of Ethics is distributed to each employee and IAR at the time of hire/contract and thereafter
as it is modified. In addition, HWP requires an annual certification by all employees/IARs regarding their
understanding and compliance with the Code of Ethics. HWP also supplements the Code of Ethics with
annual training and ongoing monitoring of employee activity.
A copy of our Code of Ethics will be provided to any client or prospective client upon request. You may
contact our Chief Compliance Officer at 225-778-7972.
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Participation or Interest in Client Transactions
From time to time, representatives of HWP may buy or sell securities for themselves that they also
recommend to clients. This may provide an opportunity for representatives of HWP to buy or sell the same
securities before or after recommending the same securities to clients resulting in representatives profiting
off the recommendations they provide to clients. Such transactions may create a conflict of interest. HWP
will always document any transactions that could be construed as conflicts of interest and will never engage
in trading that operates to the client’s disadvantage when similar securities are bought or sold.
ITEM 12: BROKERAGE PRACTICES
HWP does not maintain custody of your assets (that we manage/on which we advise), although we may be
deemed to have custody of your assets if you give us authority to withdraw assets from your account. Your
assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We
recommend that our clients select either Schwab, LPL or Fidelity Brokerage Services LLC as their qualified
custodian.
We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets
in a brokerage account and buy and sell securities when we/you instruct them to. While Schwab is a
recommended custodian/broker-dealer, you will decide which custodian to use and will open your account
directly with the selected custodian by entering into an account agreement with them. Conflicts of interest
associated with this arrangement are described below as well as in Item 14. You should consider these
conflicts of interest when selecting your custodian.
LPL Financial is the other broker-dealer selected by HWP for the conduct of its commission-based
brokerage business and to provide custodial services for advisory accounts held on LPL platforms. Factors
considered in selecting LPL include the stability and size of LPL, along with the variety of programs and
flexibility in commission rates IARs may charge. HWP receives referral bonuses from LPL, which are
based on the trailing 12-month commission production history of newly hired IARs, as well as a percentage
portion of the commissions and bonuses the IARs generate at LPL. HWP has also selected Charles Schwab
as broker-dealers to provide custody services for advisory accounts in specific cases where the client would
be best served. Factors considered in selecting these firms include stability, reputations, trading platforms,
and continuing with a current custodian.
Recommendation of LPL
HWP may request that clients establish a brokerage account with LPL Financial to maintain custody of
client’s assets and to effect trades for their accounts. LPL provides brokerage and custodial services to
independent investment advisory firms, including HWP. For HWP’s accounts custodied at LPL Financial,
LPL generally is compensated by clients through commissions, trails, or other transaction-based fees for
trades that are executed through LPL or that settle into LPL. For IRA accounts, LPL Financial generally
charges account maintenance fees. In addition, LPL also charges clients miscellaneous fees and charges,
such as account transfer fees.
Clients should also understand that LPL Financial is responsible under FINRA rules for supervising certain
business activities of HWP and its Dually Registered Persons that are conducted through broker-dealers and
custodians other than LPL Financial. LPL Financial charges a fee for its oversight of activities conducted
through these other broker-dealers and custodians. This arrangement presents a conflict of interest because
HWP has a financial incentive to recommend the use of LPL Financial rather than other broker-dealers or
custodians in order to avoid incurring the oversight fee.
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Transition Assistance Benefits. LPL Financial provides various benefits and payments to Dually Registered
Persons that are new to the LPL Financial platform to assist them with the costs (including foregone
revenues during account transition) associated with transitioning their businesses to the LPL Financial
platform (collectively referred to as “Transition Assistance”). The proceeds of such Transition Assistance
payments are intended to be used for a variety of purposes, including (but not necessarily limited to) providing
working capital to assist in funding the Dually Registered Person’s business, satisfying any outstanding
debt owed to the Dually Registered Person’s prior firm, offsetting account transfer fees (“ACATs”) payable
to LPL Financial as a result of the Dually Registered Person’s clients transitioning to LPL’s custodial
platform, technology set-up fees, marketing and mailing costs, stationary and licensure transfer fees,
moving expenses, office space expenses, staffing support, and termination fees associated with moving
accounts.
The amount of the Transition Assistance payments is often significant in relation to the overall revenue
earned or compensation received by the Dually Registered Person at their prior firm. Such payments are
generally based on the size of the Dually Registered Person’s business established at the prior firm and/or
assets under custody. Please refer to the relevant ADV Part 2B Brochure Supplement for more information
about the specific Transition Payments your IAR receives.
Transition Assistance payments and other benefits are provided to associated persons of HWP in their
capacity as registered representatives of LPL Financial. However, the receipt of Transition Assistance by
such Dually Registered Persons creates a conflict of interest relating to HWP’s advisory business. In certain
instances, the receipt of such benefits is dependent on a Dually Registered Person maintaining its clients’
assets with LPL Financial, and therefore HWP has an incentive to recommend that clients maintain their
account with LPL Financial in order to generate such benefits.
HWP attempts to mitigate these conflicts of interest by evaluating and recommending that clients use LPL
Financial’s services based on the benefits that such services provide to our clients rather than the Transition
Assistance earned by any particular dually-registered person. HWP considers LPL Financial’s stability and
size, along with the variety of programs and flexibility in commission rates IARs may charge when
recommending or requiring that clients maintain accounts with LPL. However, clients should be aware of
this conflict and take it into consideration in making a decision regarding whether to custody their assets in a
brokerage account at LPL Financial.
Recommendation of Schwab
HWP may recommend that clients establish brokerage accounts with the Schwab Advisor Services division
of Schwab, a registered broker-dealer, and member SIPC, to maintain custody of client’s assets and to effect
trades for their accounts. The final decision to custody assets with Schwab is at the discretion of the IAR’s
clients, including those accounts under ERISA or IRA rules and regulations, in which case the client is
acting as either the plan sponsor or IRA accountholder. HWP is independently owned and operated and not
affiliated with Schwab.
Schwab provides HWP with access to its institutional trading and custody services, which are typically not
available to Schwab retail investors. These services generally are available to independent investment
advisors on an unsolicited basis, at no charge to them, so long as a total of at least $10 million of the
advisor’s clients’ assets are maintained in accounts at Schwab Advisor Services.
Schwab’s services include brokerage services that are related to the execution of securities transactions,
custody, research (including that in the form of advice), analyses and reports, and access to mutual funds
and other investments that are otherwise generally available only to institutional investors or would require a
significantly higher minimum initial investment.
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For HWP 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 Schwab or that settle into Schwab accounts.
Schwab also makes available to HWP other products and services that benefit HWP but may not benefit its
clients’ accounts. These benefits may include national, regional, or HWP-specific educational events
organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional
business entertainment of personnel of HWP by Schwab Advisor Services personnel (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 HWP 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
access to research, pricing information, and other market data; facilitate payment of HWP’s 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 HWP’s
accounts, including accounts not maintained at Schwab Advisor Services. Schwab Advisor Services also
makes available to HWP other services intended to help HWP 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,
Schwab may make available, arrange and/or pay vendors for these types of services rendered to HWP by
independent third parties. Schwab Advisor Services may discount or waive fees it would otherwise charge
for some of these services or pay all or a part of the fees of a third- party providing these services to HWP.
While, as a fiduciary, HWP endeavors to act in its client’s best interests, HWP’s recommendation that clients
maintain their assets in accounts at Schwab may be based in part on the benefit to HWP 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 Schwab, which creates a conflict of interest.
Best Execution
Depending on specific client needs, one broker-dealer or custodian may offer better transaction costs/order
processing than another, and those differences are evaluated by the IAR prior to opening a client account.
HWP, as an investment adviser, owes a legal and fiduciary duty to its clients, including a duty to seek best
execution of client transactions and to make full and fair disclosure to clients about any soft dollar
arrangements. While best execution policies of the custodians are monitored, they are not the only
determining factor that would influence opening an account at one custodian or another. Important items
like stability, reputation, research, trading platforms, administrative efficiencies, client-friendly statements,
and other service-oriented tasks are also considered in the evaluation and selection of a custodian. The
lowest-cost trade execution is not always the determining factor for the selection of a custodian. However,
the client has the right to inquire about opening accounts at these various institutions.
HWP is assessed an “oversight fee” by LPL Financial based on all assets held away from LPL. This fee is
passed on to the IAR of record. This is a conflict of interest because IARs have a financial incentive to
recommend the use of LPL Financial as the broker-dealer custodian for client accounts to avoid being
assessed this fee.
In connection with TPM programs, the TPM sponsor may require that clients direct brokerage to a broker-
dealer, including the TPM sponsor, or broker-dealer affiliated with the TPM sponsor. Clients should
understand that not all advisors require their clients to direct brokerage. By directing brokerage to a broker,
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clients may be unable to achieve the most favorable execution of client transactions and may pay more in
transaction charges than other broker-dealer firms. Therefore, directed brokerage may cost clients more
money. For more information about the brokerage practices of a TPM sponsor, clients should refer to the
Disclosure Brochure for the applicable TPM.
In some cases, TPMs pay additional marketing payments to HWP, its employees and/or IARs to cover fees
to attend conferences or reimbursement of expenses for workshops, seminars presented to IAR’s clients, or
advertising, marketing, or practice management. This is a conflict of interest in that IAR’s have an incentive
to recommend a TPM for which they may receive additional marketing payments. Which are commonly
referred to as “directed brokerage”). Directed brokerage represents situations in which HWP provides
advisory services but the client determines which broker-dealer is responsible for trade execution of orders.
As a result, HWP does not have obligations regarding best execution and investors selecting directed
brokerage arrangements may not benefit from opportunities existing in connection to trading that non-
directed brokerage investors may participate in.
Aggregation
When a Client authorizes discretionary management, HWP is authorized in its discretion to aggregate
purchases and sales and other transactions made for the account with purchases and sales and transactions
in the same securities for other Clients of HWP. All Clients participating in the aggregated order shall
receive an average share price with all other transaction costs shared on a prorated basis. If aggregation is
not allowed or infeasible and individual transactions occur (e.g., withdrawal or liquidation requests, odd-
late trades, etc.) an account could potentially be assessed higher costs or less favorable prices than those
where aggregation has occurred. HWP will always attempt to aggregate orders whenever it has the
opportunity to do so.
ITEM 13: REVIEW OF ACCOUNTS
Frequency and Nature of Periodic Reviews and Who Makes Those Reviews
Account reviews are performed at least annually by an IAR of HWP. Account reviews are performed more
frequently when market conditions dictate. Reviews of Client accounts include, but are not limited to, a
review of Client documented risk tolerance, adherence to account objectives, investment time horizon, and
suitability criteria, reviewing target allocations of each asset class to identify if there is an opportunity for
rebalancing, and reviewing accounts for tax loss harvesting opportunities.
Financial plans are updated as requested by the Client and pursuant to a new or amended agreement, HWP
suggests updating at least annually.
Factors That Will Trigger a Non-Periodic Review of Client Accounts
Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment
information, and changes in a Client’s own situation.
Content and Frequency of Regular Reports
Clients receive written account statements no less than quarterly for managed accounts. Account statements
are issued by the Client’s custodian. Client receives confirmations of each transaction in account from
Custodian and an additional statement during any month in which a transaction occurs. HWP may also send
periodic or other event-inspired reports based on market or portfolio activity. Reports will generally be
provided in electronic format.
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ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION
Client Referrals
HWP enters into agreements with individuals or organizations that refer Clients to HWP in exchange for
compensation. All such agreements will be in writing and comply with the requirements of the applicable
state and federal regulations. If a Client is introduced to HWP by a solicitor, HWP may pay that solicitor a
fee. The specific terms of each agreement may differ, generally, the compensation will be a flat fee per
referral or a percentage of the introduced capital. Any such fee shall be paid solely from HWP’s investment
management fee and shall not result in any additional charge to the Client.
Other Compensation
We receive an economic benefit from Schwab in the form of the support products and services it makes
available to us and other independent investment advisors whose clients maintain accounts at Schwab. You
do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit
from the referral arrangement because the cost of these services would otherwise be borne directly by us.
You should consider these conflicts of interest when selecting a custodian. The products and services
provided by Schwab, how they benefit us, and the related conflicts of interest are described above (See Item
12).
HWP receives referral bonuses from LPL which are based on the trailing 12-month commission production
history of newly hired IARs, as well as a percentage portion of the commissions and bonuses they generate
at LPL. Some newly hired IARs may receive from LPL forgivable loans, upfront cash and various forms of
start-up expense coverage based on their trailing 12-month commission production history for electing to
join LPL and HWP. This is a conflict of interest in that it provides an incentive for the representative to
change firms in order to obtain these forms of compensation.
HWP and/or its Dually Registered Persons are incentivized to join and remain affiliated with LPL Financial
and to recommend that clients establish accounts with LPL through the provision of Transition Assistance
and this is a conflict of interest. LPL also provides other compensation to HWP and its Dually Registered
Persons, including, but not limited to, bonus payments, repayable and forgivable loans, stock awards, and
other benefits. The receipt of any such compensation creates a financial incentive for the IAR to recommend
LPL Financial as custodian for the assets in a client’s account, and thus it is a conflict of interest. We
encourage the client to discuss any such conflicts of interest with their representative before making a
decision to custody their assets at LPL Financial.
Some IARs and HWP employees receive additional non-cash compensation from advisory product sponsors.
Such compensation is not always tied to the sale of any products. Compensation includes, but is not limited
to, such items as gifts valued at less than $100 annually and entertainment, such as an occasional dinner or
ticket to a sporting event, or reimbursement in connection with educational meetings or marketing or
advertising initiatives. Advisory product sponsors also pay for education or training events that may be
attended by HWP employees and IARs.
The IAR recommending a TPM program to the client receives compensation as a result of the client’s
participation in the program. This compensation includes a portion of the advisory fee and also may include
other compensation, such as awards, or other things of value offered by the TPM to the IAR. For example,
a TPM may pay additional marketing payments to HWP, its employees and/or IARs to cover fees to attend
conferences or reimbursement of expenses for workshops, seminars presented to the IAR’s clients or
advertising, marketing, or practice management. The amount of this compensation may be more or less than
what the IAR would receive if the client participated in LPL advisory programs, programs of other
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August 2025
investment advisors or paid separately for investment advice, brokerage, and other client services.
Therefore, this is a conflict or interest in that the IAR may have a financial incentive to recommend a TPM
program account over other programs and services.
HWP has entered into referral agreements with independent TPMs, pursuant to which HWP and IARs
receive referral fees from the TPMs in return for referrals of clients. Because HWP is engaged by and paid
by the TPM for the referral, any recommendation regarding a TPM as part of a referral presents a conflict of
interest. HWP addresses this conflict by providing the client with a disclosure statement explaining the role
of HWP, the IAR and the referral fee received by HWP and the IAR.
In some cases, the TPMs pay additional marketing payments to HWP, its employees and/or IARs to cover
fees to attend conferences or reimbursement of expenses for workshops, seminars presented to the IAR’s
clients or advertising, marketing, or practice management.
Load and no-load mutual funds may pay annual distribution charges (sometimes referred to as 12b-1 fees).
12b-1 fees come from fund assets; therefore, indirectly from client assets. Any 12b-1 fees paid on mutual
funds purchased in a HWP managed account are not passed on to IARs and will be retained by LPL.
LPL makes available to HWP other products and services that benefit HWP but may not benefit its clients’
accounts. Some of these other products and services assist HWP in managing and administering clients’
accounts. These include: software and other technology that provide access to client account data (such as
trade confirmations and account statements); the facilitation of trade execution and allocation of aggregated
trade orders for multiple client accounts; research, pricing information and other market data; the facilitation
of payment of HWP’s fees from its clients’ accounts; and assistance with back-office functions,
recordkeeping, and client reporting. Many of these services generally may be used to service all or a
substantial number of HWP’s accounts, including those accounts not maintained at LPL. LPL may also
make available to HWP other services intended to help HWP manage and further develop its business
enterprise. These services may include consulting, publications, and conferences on practice management;
information technology; business succession; regulatory compliance; and marketing. In addition, LPL may
make available, arrange and/or pay for these types of services rendered to HWP by independent third parties.
LPL may discount or waive fees it would otherwise charge for some of these services or pay all or a part of
the fees of a third party providing these services to HWP.
ITEM 15: CUSTODY
When it deducts fees directly from client accounts at a selected custodian, HWP will be deemed to have
limited custody of client’s assets and must have written authorization from the client to do so. Clients will
receive all account statements that are required in each jurisdiction, and they should carefully review those
statements for accuracy.
Custody is also disclosed in Form ADV because HWP has authority to transfer money from client
account(s), which constitutes a standing letter of authorization (SLOA). Accordingly, HWP will follow the
safeguards specified by the SEC rather than undergo an annual audit.
ITEM 16: INVESTMENT DISCRETION
Clients can grant HWP authorization to manage a client’s account on a discretionary basis. Discretionary
authorization provides HWP the ability to determine the securities to be purchased and sold and when such
securities are purchased and sold. Clients must complete and sign custodial paperwork to establish any
mutual fund, variable annuity, or brokerage account.
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With respect to financial planning and hourly consulting services, HWP and the IAR do not have any
discretionary investment authority.
In a third-party investment advisory (“TPM”) program, the client typically authorizes the TPM to purchase
and sell securities on a discretionary or non-discretionary basis pursuant to the investment objective chosen
by the client. This authorization will be set out in the TPM client agreement. HWP and the IAR do not have
discretion on TPM program accounts.
ITEM 17: VOTING CLIENT SECURITIES
We do not vote proxies for you. You retain the responsibility for receiving and voting proxies for securities
held in your accounts. Your account custodian will send these to you or your designee. We may provide
advice to you at your request regarding a securities proxy.
ITEM 18: FINANCIAL INFORMATION
Prepayment of Fees
The Adviser does not require or accept prepayment of more than $1,200 in fees six months or more in
advance and a balance sheet is not required to accompany this Brochure.
Financial Condition
HWP does not have a financial condition or commitment that impairs our ability to meet contractual and
fiduciary obligations to clients. Furthermore, we have never been the subject of a bankruptcy proceeding.
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