HIGHLAND INVESTMENT ADVISORS LLC

Item 1 - Cover Page (Highland Investment Advisors LLC DBA Fund Management) Form ADV Part 2A February 16, 2026 Main Office Address: 466 Town Plaza Ave, Suite 330 Ponte Vedra, FL 32081 WI Address: 175 Patrick Blvd., Suite 120 Brookfield, WI 53045 (262) 240-9750 / (414) 755-2309 office (414) 755-2313 fax (877) 755-2309 toll free adrake@highlandinvestmentadvisors.com Website: www.highlandinvestmentadvisors.com IARD/CRD #141694 This brochure provides information about the personnel and business practices of Highland Investment Advisors, LLC. This brochure has not been approved by the U.S. Securities and Exchange Commission, or by any state securities authority. If you have any questions regarding this brochure, please call us at 414-755-2309, or by email at adrake@highlandinvesmentadvisors.com. Being licensed as an Investment Advisor does not imply any level of skill or training. Additional information about Highland Investment Advisors, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Page 1  Item 2 - Summary of Material Changes This update is in accordance with the required annual update for Investment Advisors. Since the last filing of this brochure on December 5, 2024, the following material changes have occurred: Item 4 assets under management calculation updated. Item 8 updated to disclose direct indexing. • • • We have changed our custodian to Charles Schwab & Co., Inc. Item 3 – Table of Contents Table of Contents Item 4 Advisory Business .......................................................................................................................... 3 Item 5 Fees and Compensation ................................................................................................................. 3 Item 6 Performance-Based Fees and Side-By-Side Management ...................................................... 5 Item 7 Types of Clients ............................................................................................................................... 5 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 5 Item 9 Disciplinary Information .............................................................................................................. 7 Item 10 Other Financial Industry Activities and Affiliations ............................................................. 8 Item 11 Code of Ethics, Participation or Interest in Client Transaction and Personal Trading . 9 Item 12 Brokerage Practices .................................................................................................................. 10 Item 13 Review of Accounts .................................................................................................................... 10 Item 14 Client Referrals and Other Compensation ............................................................................ 11 Item 15 Custody ......................................................................................................................................... 11 Item 16 Investment Discretion ............................................................................................................... 11 Item 17 Voting Client Securities ............................................................................................................. 12 Item 18 Financial Information ................................................................................................................ 12 Page 2  Item 4 Advisory Business A. Fund Management Corporation (FMC) was founded by Paul A. Presti in 1984. On November 18, 2014, Fund Management Corporation entered into a purchase agreement with Highland Investment Advisors, LLC (HIA). B. Effective December 31, 2020, FMC was dissolved as a Wisconsin corporate entity and withdrew its registration as an IARD investment advisor. On January 1, 2021, former clients of FMC were reassigned to Highland Investment Advisors, LLC. DBA Fund Management. (“FM”) C. FM provides investment advice primarily for securities, including but not limited to mutual funds, exchange trades funds (ETF), closed end funds (CEF), and individual securities which are relevant to meet the individual needs of the client. FM continuously evaluates the investment recommendations to be consistent with the investment objectives and risk tolerance of the client. D. FM also provides financial planning services to its investment advisory clients upon request. Financial planning may include, but is not limited to: retirement planning, education, cash flow analysis, estate planning, insurance planning, investment management, and tax planning. Clients are not charged for financial planning services E. FM does not participate in wrap fee programs. F. As of December 31, 2025, HIA had approximately $367,287,227 in discretionary client assets under management and $980,633 in non-discretionary assets under management. Item 5 Fees and Compensation Advisory fees are paid in advance quarterly based on total client household assets under management at quarter end. This Schedule may be amended from time to time by the Adviser upon thirty (30) days’ written notice to the Client: Advisory fees are charged according to the following fee schedule: Account Objective: Equity based $ 0 to $ 99,999 Annual Fee as % of Total Assets 1.75% Page 3  $100,000 to $149,999 $150,000 or greater Account Objective: Income based All dollar amounts 1.25% 1.00% Annual Fee as % of Total Assets 0.50% Fee Calculation Examples: Total Asset Value of Account Fee % Fee Paid (annualized) $140,000 - Equity 1.25 $150,000 – ½ Equity + ½ Income 0.75 $150,000 - Income 0.5 $1,750 $1,125 $750 A. FMC bills clients quarterly, on a forward basis at the beginning of each calendar quarter. Advisory fees are calculated based on the market value of investments under management as of the just completed quarter end. For new client accounts opened mid- quarter, management fees are prorated from the date assets are transferred into the account. Management fees are not assessed on accounts open less than 15 calendar days during the quarter. B. The basic fee schedule is negotiable and may vary based on the scope of the total relationship between FM and the client. Fees may vary based on factors such as; client type, account objective, pre-existing relationship, service levels, portfolio complexity, account size or other special circumstances or requirements. Some existing clients may pay lower fees than newer clients. C. Clients may choose to pay fees or have the fees deducted directly from their account. Clients whose fees are withdrawn from a custodian account authorize the custodian to pay FM the fees due from the client’s assets. FM agrees to notify the client in writing, by at least first class mail, the exact amount of the withdrawal based on the above Fee Schedule. The custodian shall notify the Client as least quarterly of the amount that has been paid to FM. The Client, rather than the custodian, shall verify the accuracy of FM’s fee calculation. D. All mutual funds and other pooled investments such as ETFs pay fees for portfolio management services which reduce the net asset value of the fund’s shares. In addition, FM bills its clients an advisory fee based on the value of their total portfolio. Additionally, the Client may have to pay fees charged by the custodian such as transaction fees, account closing fees, etc. E. FM does not accept commissions for the sale of investment securities. Page 4  Item 6 Performance-Based Fees and Side-By-Side Management All advisory fees charged by FM are based on a percentage of the assets under management. FM does not charge fees based upon performance. Item 7 Types of Clients FM provides investment advice to individuals, corporations and other business entities. As of January 1, 2021, the minimum account size of new accounts is $100,000. This minimum may be waived in certain instances. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis: FM’s method of analysis is based on a combination of fundamental, technical and psychological factors. Fundamental Analysis – Fundamental analysis incorporates a broad array of economic indicators. This would include analyzing the overall health of the economy based on such indicators as GDP (gross domestic product), LEI (leading economic indicators), manufacturing indexes, service center indexes, and monthly economic conditions known as the Federal Reserve Board’s (Fed) “beige book” reported by twelve districts across the nation. Inside the more broadly based economic reports, more specific information on retail sales, home sales, employment, auto sales, factory orders, consumer sentiment, etc. is analyzed. The broad economic indicators provide insight into corporate earnings projections, along with the direction of interest rates. Review of other leading indicators, such as the ECRI (Economic Cycle Research Institute) which act as a precursor to expansion or contraction of the economy, helps to determine its direction. The fundamentals help to provide the direction of interest rates as to whether the Fed provides easy money (expansionary) or tight money (contracting environment). The fundamental underpinnings provide insight for stock analysts, corporate earnings projection, dividends and valuation levels. Technical Analysis – This method primarily utilizes information in chart form to determine market information. This analysis employs many techniques to determine the underlying basic market trend. The technical aspects confirm the Page 5  directional trend whether it be up, down or sideways environment. Reviewing the internal workings of the market include volume, stocks hitting new highs and new lows and advance-decline data,e.g. number of stocks advancing minus declining stocks provides a positive increasing or negative declining trend. Trend analysis is also performed on various sectors of the stock market such as basic materials, financial stocks, etc. and how they compare to the major financial averages such as the Dow Jones Industrials, Dow Jones Transports, Dow Jones Utilities, and the NASDAQ index. Cycle research is also utilized as it pertains to the business cycle (expansion or contraction), presidential election cycle, and decennial cycle (10- year) patterns. Combining various elements of technical indicators helps to provide a systematic approach to trend interpretation. Psychological Analysis - Market psychology or market sentiment is a feeling the market is expressing at any particular time. Greed, fear, expectations and circumstances are all factors that contribute to the group’s investing mentality. This is usually a contrary indicator. Surveys taken from newsletter writers, individual investor’s surveys, option players, etc. are used for the basis of this analysis. When the public is euphoric, the market risk proves to be high. The majority of market participants have already bought and valuations levels are usually extended. Conversely, when the majority of participants become pessimistic, depressed, and selling is at extremes, the market environment is usually less risky. Risk of Loss: Although FM utilizes a broadly diversified approach to investing, there is always a material or market risk when investing in stocks or bonds. Clients should be prepared to bear losses any time they have exposure to stock or bond markets. By using a broadly diversified approach, a client could underperform market equity indexes in a strong rising market. Conversely, the client may have a reduced exposure to market indexes in a declining market. B. Investment Strategy: FM investment strategy seeks long term growth of capital appreciation and/or income (or total return) with an emphasis on risk control to obtain prudent investment returns over a longer period of time. This is accomplished by investing the portfolio in a number of diversified investments to meet the client’s investment objectives. This includes investing in securities in a wide range of asset classes in the United States and around the world. Some of these funds might be classified as “flexible funds” or “strategic asset allocation funds” that allocate investments among common stocks (large, mid, small-cap), both domestically and internationally, in addition to bonds and other debt instruments; such as US Treasury notes and bonds, investment grade corporate bonds, and debt securities below investment grade, in addition to money market instruments. Investment in a number of diversified and global allocation funds across a broad spectrum of stocks, bonds and cash helps to further mitigate Page 6  unnecessary risk. In addition, FM offers “Direct Indexing” strategies. Direct indexing is an investment approach that seeks to replicate the performance of a designated securities index by directly purchasing some or all of the individual equity securities comprising that index, rather than investing in a mutual fund or exchange- traded fund (“ETF”) that tracks the index. FM constructs and manages customized portfolios designed to approximate the risk and return characteristics of a selected benchmark index (e.g., S&P 500, Russell 1000, or other broad or customized indices). Depending on account size, liquidity, and client-specific constraints, FM may not purchase all securities in the index and instead may use optimization, sampling, or other portfolio construction techniques to seek similar exposure. C. Mutual fund holdings are sold for various reasons. In the event the mutual fund in question underperforms its investment objective for a period of time, the fund could be sold. Also a change in investment management might prove detrimental to the fund’s performance and would be reason for liquidation. Various core holding funds might be held for a number of years or longer. During significant market events, fund holdings could be partially reduced for preservation of capital. There are no significant or unusual risks or frequent trading associated with the type of investment strategy employed. Item 9 Disciplinary Information Neither FM nor any of its associates is currently, or have ever been, subject to: A. Criminal or civil action in a domestic, foreign or military court of competent jurisdiction; nor have they: 1. ever been convicted of, or plead guilty or nolo contendere (“no contest”) to (a) any felony; (b) a misdemeanor that involved investments or an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses; 2. ever been named the subject of a pending criminal proceeding that involves an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion; or a conspiracy to commit any of these offenses; 3. ever been found to have been involved in a violation of an investment-related statute or regulation; or 4. ever been the subject of any order, judgment, or decree permanently or temporarily enjoining, or otherwise limiting, FM or a management person from engaging in any investment-related activity, or from violating any investment- related statute, rule or order. Page 7  B. An administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority, nor have they 1. been found to have caused an investment-related business to lose its authorization to do business; or 2. been found to have been involved in a violation of an investment-related stature or regulation or been the subject of an order by the agency or authority (a) denying, suspending, or revoking the authorization of FM or a management person to act in an investment-related business; (b) barring or suspending FM’s or a management person’s association with an investment- related business; (c) otherwise significantly limiting FM’s or a management person’s investment-related activities; or imposing a civil money penalty of more than $2,500 on FM or a management person. C. A self-regulatory organization (SRO) proceeding nor were they 1. found to have caused an investment-related business to lose its authorization to do business; or 2. found to have been involved in a violation of the SRO’s rules and were: (i) barred or suspended from membership or from association with other members or were expelled from membership; (ii) otherwise significantly limited from investment- related activities; or (iii) fined more than $2,500. Item 10 Other Financial Industry Activities and Affiliations Neither FM nor any of its associates: A. have an application pending to register as a broker/dealer or registered representative of a broker/dealer. B. are registered, or have an application pending to register, as futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. C. have any relationship or arrangement that is material to its advisory business or its clients that would create a material conflict of interest with clients. D. On November 18, 2014, FMC entered into a purchase agreement with HIA wherein FMC became a wholly owned subsidiary of HIA. Effective January 1, 2021, FMC clients were reassigned to Highland Investment Advisors LLC DBA Fund Management (“FM) as a result of HIA restructuring. Page 8  Item 11 Code of Ethics, Participation or Interest in Client Transaction and Personal Trading A. Code of Ethics - FM has a legal fiduciary duty to its clients and endeavors at all times to put the interests of its clients first. B. FM is an SEC-registered adviser, and has developed a Code of Ethics designed to detect and prevent violations of applicable investment advisory laws, and to ensure compliance with the internal policies and procedures of FM such as: protection of material non-public client information; supervision of personal securities trading activity; and identification of, and prevention of, using insider information. Employees of FM have received a copy of the Code of Ethics and acknowledge having read and understood it. A copy of the Code of Ethics is available to existing and prospective clients upon request. C. FM’s Code of Ethics is applicable to all employees who either participate in the formulation or delivery of investment advisory services to clients or otherwise have access to confidential client records or to recommendations being made for client accounts (“access persons”). The Code of Ethics sets forth procedures intended to prevent conflicts of interest between clients and our access persons, and is designed to comply with Rule 204A-1 under the Investment Advisers Act of 1940 and rules of individual jurisdictions. This Code establishes rules of conduct for all of our access persons and is designed among other things to govern personal securities trading activities in the account of access persons. The Code is based upon the principle that FM owes a fiduciary duty to its clients. This requires that all access persons conduct the affairs of FM, including personal securities transactions, in such a manner as to avoid (1) serving personal interests ahead of clients, (2) taking inappropriate advantage of positions within the firm, and (3) any actual or potential conflicts of interest or abuse of positions of trust and responsibility. D. FM prohibits employees or associated persons from recommending any investment wherein FM is incentivized or would derive any economic benefit, directly or indirectly, other than our normal advisory fee. Neither FM nor any of its employees recommends to clients, or buys or sells for client accounts, securities in which FM, affiliated firms, or any of its employees or associates has a material financial interest. E. FM and its employees may buy or sell for themselves, securities that are also recommended to clients. FM believes such transactions do not have a significant Page 9  impact on market prices of the securities or client opportunities in those securities. FM employees are prohibited from purchasing or selling for themselves the same securities (with the exception of mutual funds, or exchanged traded funds) purchased or sold for clients’ accounts within two business days of such client purchase or sale. F. If transactions by FM or any of its employees are likely to have a significant impact on market prices, no transactions will be made by FM or its employees until the client's transactions have been entered. If the position in a security held by FM or its employees is significant, the client will be informed of these positions. F. FM maintains a list of all securities purchased for itself or its employees, and all securities transactions are reviewed on a regular basis by Adam Drake, President. G. A copy of our Code of Ethics is available upon request. Item 12 Brokerage Practices A. FM recommends Charles Schwab & Co., Inc. (“Schwab”) as the client’s broker/dealer based upon our belief that Schwab offers an exceptional value to the client due to the high quality of the electronic interface between the broker and FM. This allows greater productivity and efficiency in the conduct of the Client’s account. FM suggests broker/dealers to clients based primarily on competitive transaction costs and FM attempts to minimize all investment related expenses as a paramount factor in its work on behalf of its clients. FM does not consider client referrals when selecting a broker/dealer. FM does not receive any soft dollar benefits for using Schwab. Additionally, FM does not receive client referrals from Schwab. Other broker/dealers may be used if it is a requirement of the account, such as in the case of an employer sponsored retirement plan, etc. In these cases, FM may not be able to achieve the most favorable execution of client transactions which may cost the client more money, for example, higher commissions. B. FM does not aggregate mutual fund purchases. All assets are held individually by account owners. Item 13 Review of Accounts Page 10  A. FM investment advisors continuously evaluate investment recommendations and portfolio composition to be compatible with the personal financial objectives, risk tolerances and goals of the client. B. Since accounts are only invested in publicly traded securities, they can be expeditiously reviewed and quickly adjusted if necessary. All clients’ securities pricing is obtained electronically daily. C. Clients receive account statements from their custodian at least quarterly showing the value of the account and account holdings as of the statement end date. FM also provides condensed account statements on a quarterly basis showing account balances and performance. Ad hoc account reports are available upon request. Item 14 Client Referrals and Other Compensation A. Neither FM nor any employee or representative of FM receives compensation or any other economic benefit for client referrals. B. Neither FM nor any employee or representative of FM directly or indirectly compensates any unrelated entity for client referrals. Item 15 Custody Under no circumstances will FM have custody of client funds or securities. All client funds and securities are held by a broker/dealer or qualified custodian who provides clients with a statement of their account at least quarterly. Clients should compare information contained in FM’s statement with the statement received from the qualified custodian for accuracy. Item 16 Investment Discretion All accounts managed by FM are discretionary. FM requires a signed Limited Power of Attorney from each client. The Limited Power of Attorney enables FM to buy and sell shares of securities without first receiving approval from the client. Page 11  Item 17 Voting Client Securities A. As a matter of firm policy and practice, FM does not have any authority to, and does not vote proxies on behalf of advisory clients. B. Clients are responsible for receiving and voting proxies for any and all securities maintained in their portfolios. Item 18 Financial Information A. FM does not require or solicit prepayment of any dollar amount per client six months or more in advance. B. FM does not solicit prepayment of more than $1,200 in fees per client six months or more in advance, and therefore, is not required to submit a financial statement audited by an independent public accountant. C. FM has not been the subject of a bankruptcy petition at any time during the past ten years or at any time prior to that. Page 12  Highland Investment Advisors, LLC Client Relationship Summary (“Form CRS”) February 16, 2026 Highland Investment Advisors, LLC (“Highland”), also doing business as Highland Investment Advisors, LLC DBA Fund Management (“Fund Management”), is a federally registered Investment Advisor with the US Securities & Exchange Commission (SEC). Investment advisory services and fees differ from broker-dealers, and it is important for you to understand the differences. Free and simple tools are available to research firms and financial professionals at www.Investor.gov/CRS, which also provides educational materials about broker-dealers, investment advisors, and investing. What investment services and advice can you provide to me? Conversation Starters: Given my financial situation, should I choose an investment advisory service? Why or why not? How will you choose investments to recommend to me? What is your relevant experience, including your licenses, education and other qualifications? What do these qualifications mean? As a fiduciary, Highland offers comprehensive financial planning and discretionary investment advisory services to individuals and their trusts and estates (“you”, “clients”, or our “retail investors”). This includes services such as retirement planning and ongoing investment portfolio management. Our services may also include education planning, budgeting, and, when coordinating with outside professionals, tax and estate planning. We rely upon client submitted data which we do not independently verify when we provide these services. We manage portfolios based on each client’s unique investment objectives, risk tolerance, investment time horizon, withdrawal requirements and other special circumstances. We monitor your portfolio, investment strategy, and investments on at least a quarterly basis. Monitoring is a standard service we provide. Your portfolio is managed on a discretionary basis, which means we have the authority to buy and sell investments in your account without speaking to you prior to doing so. We will contact you at least annually to discuss your investments and financial plan. Although we have access to a very broad spectrum of investments, we do not have to limit the scope of securities that we use in managing client accounts. However, we generally construct our client portfolios using a combination of no-load mutual funds or exchange traded funds (“ETFs”). In some limited instances we may include individual stocks, bonds, no load annuities, or CD’s, based upon the unique needs of the client and portfolio. Buying or selling some types of these securities may result in you paying commissions to the custodian. Our account minimum is $500,000, although we may waive that amount under certain conditions, such as client extended family members. For additional information about our advisory business and clients we serve please see Item 4 and Item 7 of our Form ADV, Part 2A Brochure here: http://www.highlandinvestmentadvisors.com/brochure What fees will I pay? Conversation Starters: If I give you $10,000 to invest, how much will go to fees and costs and how much will be invested for me? Help me understand how these fees and costs might affect my investments. Retail investors pay a quarterly asset-based fee for our services. Our advisory fee is calculated based upon your assets under our management including cash and securities in your account. Fees are determined based on aggregate account valuation and range from 0.45% to 1.75% annually. Fees may be negotiable based upon account size, scope/complexity, services offered, or client type. We may also charge an hourly fee for financial planning. We only receive fees from you, our client. We do not accept commissions or receive other sources of revenue from any third parties in connection with our services. The fee we charge is based on the value of your account. Therefore, we have an inherent conflict because our interests would be best served by making recommendations that result in either retaining or increasing assets under management. Clients should understand that financial planning recommendations such as paying off a mortgage, or A copy of our Form ADV Part 2A is available at www.highlandinvestmentadvisors.com/brochure  withdrawing money for other reasons, reduce our assets under management, thus creating a conflict of interest. Highland Investment Advisors, LLC Client Relationship Summary (“Form CRS”) February 16, 2026 Your account will be held with a custodian, such as Charles Schwab & Co., Inc. Custodians charge transaction costs, brokerage commissions, and potentially other account service fees, which are in addition to the fees you pay us. These custodian fees are paid to the custodian, not us. Some securities which may be bought for your account may include mutual funds and ETFs. These securities charge their own fees. You will pay these fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying. Please see Item 5.A., B., C., and D., of our Form ADV, Part 2A Brochure. What are your legal obligations to me when acting as my investment advisor? How does your firm make money and what conflicts of interest do you have? Conversation Starters: How might your conflicts of interest affect me, and how will you address them? When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. Here are some examples to help you understand what this means: Custodians provide free services to us, including; access to research, access to conferences, and practice management services. These services may give us an incentive to recommend that clients maintain accounts with these custodians. For more detailed information about our conflicts of interest, please review our Form ADV Part 2A. How do your financial professionals make money? Conversation Starters: How do you make money? How do I pay you? Our financial professional’s compensation is based on the total amount of client fees generated by the accounts we manage. We may also receive hourly fees for financial planning services provided to clients with whom we have no investment management relationship. Do you or your financial professionals have legal or disciplinary history? Conversation Starters: As a financial professional, do you have any disciplinary history? If so, for what type of conduct? No for our firm. Yes for our financial professionals. Please visit www.Investor.gov/CRS for a free and simple search tool to research our firm and our financial professionals. Where can I get additional information? Conversations Starters: Who is my primary contact person? Is he or she a representative of an investment adviser or a broker-dealer? Who can I talk to if I have concerns about how this person is treating me? Call us at 414-755-2309 x-100 at any time to request a current copy of our Form CRS or Form ADV Part 2A and 2B. Retail investors can find additional information about our investment advisory services by calling us, or visiting our firm’s website at http://www.highlandinvestmentadvisors.com/brochure. Additional information about our firm and financial professionals can also be found at: https://brokercheck.finra.org/ or www.adviserinfo.sec.gov A copy of our Form ADV Part 2A is available at www.highlandinvestmentadvisors.com/brochure  PRIVACY POLICY Highland Investment Advisors and its affiliates are committed to respecting your privacy. We value your trust and have policies and procedures in place to maintain the confidentiality and security of your personal information. We treat client information (both past and present) in a confidential manner. Information We Collect The following nonpublic information may be obtained directly from you. • Name, address, phone number and email address • Social Security or Taxpayer Identification Number • Family and general health data • Assets and liabilities • Account balances and activity • Accounts at other institutions We do not solicit information about you from other external sources. How We Use Information We obtain nonpublic information to provide you with the professional services you have requested and to properly manage and coordinate professional services for your investment account. Disclosures to Unaffiliated Third Parties We do not disclose your information to outside parties. We do not share, sell or rent your personal information. The use of, and access to, your personal information by Highland Investment Advisors, LLC is restricted to those employees who need to know that information to process transactions or provide financial services to you. We will keep information about current, former, and prospective clients confidential unless: 1) the information concerns illegal activities on the part of the client or prospective client, 2) disclosure is required by law, to comply with subpoenas, or court or government agency orders, or 3) the client or prospective client provides written permission allowing disclosure of the information. This includes disclosing information to professionals such as: attorneys, accountants, and/or financial professionals in order to provide services on your behalf. How We Protect Your Data We maintain physical, electronic and procedural safeguards to limit access to your nonpublic personal information. This includes physical and electronic data security measures, as well maintaining fault tolerant data processing capabilities. Highland Investment Advisors, LLC appreciates your business. If you have any questions or comments about this Privacy Policy, please call (414) 755-2309 x100 HIA Privacy Policy 041520.doc 

FO RM ADV PART 2 A D I S C L O S U R E B R O C H U R E (Highland Investment Advisors LLC DBA Whitman Wealth Management) Main Office Address: 466 Town Plaza Ave, Suite 330 WI Address: Ponte Vedra, FL 32081 414-755-2309 175 Patrick Blvd., Suite 120 Brookfield, WI 53045 Tel: Toll Free Tel: Fax: 877-755-2309 414-755-2313 Email: Website: adrake@highlandinvestmentadvisors.com www.highlandinvestmentadvisors.com February 16, 2026 This brochure provides information about the qualifications and business practices of Highland Investment Advisors, LLC. Being registered as an 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 414-755-2309. The information in this brochure has not been approved or verified A D D I TI O NA L I NF O R M A T I O N A B O U T HI G HL A N D I N V E S T M E N T AD V I S O RS , by the United States Securities and Exchange Commission, or by any state securities authority. L L C ( C R D # 14 16 94 ) I S AV AI L AB L E O N T H E SE C’ S WE BS I TE A T W W W . A D V I S E RI N F O .S E C . G O V  Item 2: Material Changes Annual Update Material Changes since the Last 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. • Since the last filing on February 26, 2025, the following material changes have occurred: • Item 4 has been updated to disclose the most recent calculation for assets under management calculation. • Item 5 has been updated to disclose current fees for financial planning. Item 8 has been updated to add disclosures for direct indexing. Full Brochure Available This Firm Brochure being delivered is the complete brochure for the Firm.  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 Item 3: Table of Contents ................................................................................................................... iii Full Brochure Available .................................................................................................................................................. ii 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 Item 5: Fees and Compensation ......................................................................................................... 5 Client Assets under Management ............................................................................................................................... 5 Method of Compensation and Fee Schedule .......................................................................................................... 5 Client Payment of Fees .................................................................................................................................................... 7 Additional Client Fees Charged ................................................................................................................................... 8 Prepayment of Client Fees ............................................................................................................................................. 8 Item 6: Performance-Based Fees and Side-by-Side Management .......................................... 8 External Compensation for the Sale of Securities to Clients ............................................................................ 8 Item 7: Types of Clients ........................................................................................................................ 8 Sharing of Capital Gains .................................................................................................................................................. 8 Description........................................................................................................................................................................... 8 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .................................. 9 Account Minimums........................................................................................................................................................... 9 Methods of Analysis ......................................................................................................................................................... 9 Investment Strategy ......................................................................................................................................................... 9 Item 9: Disciplinary Information ................................................................................................... 13 Security Specific Material Risks ................................................................................................................................ 11 Criminal or Civil Actions ............................................................................................................................................. 13 Administrative Enforcement Proceedings ........................................................................................................... 13  Item 10: Other Financial Industry Activities and Affiliations .............................................. 13 Self- Regulatory Organization Enforcement Proceedings ............................................................................. 13 Broker-Dealer or Representative Registration .................................................................................................. 13 Futures or Commodity Registration ....................................................................................................................... 14 Material Relationships Maintained by this Advisory Business and Conflicts of Interest .................. 14 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ............... 14 Trading .................................................................................................................................................... 15 Code of Ethics Description .......................................................................................................................................... 15 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 15 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 15 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Item 12: Brokerage Practices .......................................................................................................... 16 Transactions and Conflicts of Interest ................................................................................................................... 16 Factors Used to Select Broker-Dealers for Client Transactions .................................................................. 16 Item 13: Review of Accounts ............................................................................................................ 17 Aggregating Securities Transactions for Client Accounts .............................................................................. 17 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ............................................................................................................................................................................. 17 Review of Client Accounts on Non-Periodic Basis ............................................................................................ 17 Item 14: Client Referrals and Other Compensation................................................................. 18 Content of Client Provided Reports and Frequency ......................................................................................... 17 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ............................................................................................................................................................................... 18 Item 15: Custody .................................................................................................................................. 18 Advisory Firm Payments for Client Referrals ..................................................................................................... 18 Item 16: Investment Discretion ...................................................................................................... 19 Account Statements....................................................................................................................................................... 18 Item 17: Voting Client Securities .................................................................................................... 19 Discretionary Authority for Trading ...................................................................................................................... 19 Item 18: Financial Information ....................................................................................................... 19 Proxy Votes ....................................................................................................................................................................... 19 Balance Sheet ................................................................................................................................................................... 19 Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments  to Clients ............................................................................................................................................................................ 19 Item 19: Requirements for State Registered Advisors ........................................................... 19 Bankruptcy Petitions during the Past Ten Years ............................................................................................... 19 Principal Executive Officers and Management Persons ................................................................................. 19 Outside Business Activities ........................................................................................................................................ 20 Performance Based Fee Description ...................................................................................................................... 20 Disclosure of Material Facts Related to Arbitration or Disciplinary Actions Involving Management Persons ................................................................................................................................................... 20 Material Relationship Maintained by this Advisory Business or Management persons with Brochure Supplement (Part 2B of Form ADV)........................................................................... 22 Issuers of Securities ...................................................................................................................................................... 20 Principal Executive Officer – Adam Drake, CFA ................................................................................................. 22 Item 2 - Educational Background and Business Experience ........................................................................ 22 Item 3 - Disciplinary Information ............................................................................................................................ 22 Item 4 - Other Business Activities ........................................................................................................................... 23 Item 5 - Additional Compensation .......................................................................................................................... 23 Item 6 - Supervision ...................................................................................................................................................... 23 Item 7 - Requirements for State-Registered Advisors .................................................................................... 24  Item 4: Advisory Business Firm Description Types of Advisory Services Highland Investment Advisors, LLC (“HIA”) was founded in 2006. Adam Drake is 100% owner. Highland Investment Advisors LLC provides investment advice under Highland Investment Advisors LLC (“HIA), Highland Investment Advisors LLC DBA Fund Management (“FM”), and Highland Investment Advisors LLC DBA Whitman Wealth Management (“WWM”). Fund Management (“FM”) and Whitman Wealth Management have separate ADVs, available upon request or on our website. ASSET MANAGEMENT HIA offers discretionary and non-discretionary asset management services to advisory Clients. HIA 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. Discretionary When the Client provides HIA discretionary authority the Client will sign a limited trading authorization or equivalent. HIA 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 HIA on a non-discretionary basis, HIA will determine the securities to be bought or sold and the amount of the securities to be bought or sold. However, HIA will obtain prior Client approval on each and every transaction before executing any transaction. When deemed appropriate for the Client, HIA may hire Sub-Advisors to manage all or a portion of the assets in the Client account. HIA has full discretion to hire and fire Sub- Advisors as they deem suitable. Sub-Advisors will maintain the models or investment strategies agreed upon between Sub-Advisor and HIA. Sub-Advisors execute trades on behalf of HIA in Client accounts. HIA will be responsible for the overall direct relationship with the Client. HIA retains the authority to terminate the Sub-Advisor relationship at HIA’s discretion. HIA is an authorized provider of Dimensional Fund Advisor (“DFA”) mutual funds and may purchase and hold DFA funds in client portfolios. DFA funds are generally not available through retail investment channels. This restriction may limit a client’s ability to manage these funds should the client subsequently terminate his/her relationship with HIA. As part of the recommendations provided, the Client may have a financial plan completed. This may include but is not limited to a thorough review of all applicable topics such as Investments, Taxes, Qualified Plans, Insurance, Retirement Income, College Planning, Home Buying, Budgeting, Debt Management, Emergency Funds, and Risk Tolerance Assessment. If a conflict of interest exists between the interests of HIA and the interests of the Client, the Client is under no obligation to act upon HIA’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through HIA. This service will be provided at no additional cost to the Client. - 1 -  ASSETS HELD AWAY HIA uses a third party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive 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 Client account(s) is connected to the platform, HIA will review the current account allocations. When deemed necessary, HIA will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. FINANCIAL PLANNING AND CONSULTING Financial planning services include a comprehensive evaluation of an investor'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. HIA will use current net worth, tax liabilities, asset allocation, and future retirement and estate plans in developing financial plans. Financial goals Typical topics reviewed in a financial plan may include but are not limited to: • : Based on an individual's or a family's clearly defined financial goals, including funding a college education for the children, buying a larger home, starting a business, retiring on time or leaving a legacy. Financial goals should be quantified Personal net worth statement and set to milestones for tracking. : A snapshot of assets and liabilities serves as a • Cash flow analysis benchmark for measuring progress towards financial goals. : An income and spending plan determines how much can be set • Retirement strategy aside for debt repayment, savings and investing each month. • Comprehensive risk management plan : 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 : Identify all risk exposures and provide the necessary coverage to protect the family and its assets against financial loss. The risk management plan includes a full review of life and disability insurance, personal liability coverage, property and casualty coverage, and catastrophic coverage. • : Include a customized asset allocation strategy based on specific investment objectives and a risk profile. This investment plan sets guidelines for selecting, buying and selling investments and establishing benchmarks Tax reduction strategy for performance review. • Estate preservation : 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. • : 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. - 2 -  If a conflict of interest exists between the interests of HIA and the interests of the Client, the Client is under no obligation to act upon HIA’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through HIA. Financial plans will be completed and delivered inside of ninety (90) days contingent upon timely delivery of all required documentation. SUBSCRIPTION-BASED FINANICAL PLANNING This service involves working one-on-one with Beverly over an extended period of time. By paying the monthly fee, Clients will work with Beverly to identify and prioritize goals and develop and implement their financial plan. Upon desiring a comprehensive plan, a Client will be taken through a four or five-meeting process over two or three months to assist them in establishing their goals and values around money. They will be required to provide information to help complete the following areas of analysis: net worth, cash flow, insurance, employee benefits, retirement planning, insurance, investments, college planning, and estate planning. Once the Client's information is reviewed and data is compiled, a draft will be reviewed with the Client. Clients Point A (where they are now) is established. Once the draft is reviewed with the client, a final meeting is scheduled to address how to reach their goals or their Point B (where they are going). Clients subscribing to this service will receive a written or an electronic report, providing the Client with a detailed financial plan designed to work towards Clients’ stated financial goals and objectives. This report will include at a minimum a Net Worth Statement, ten years of cash flow statements, a Monte Carlo analysis, and recommendations. If a follow-up meeting is required, we will meet at the Client's convenience. While the implementation of the plan is solely the client’s responsibility, Beverly is available for assistance or as questions arise. On an annual basis, clients are invited for a full review of this plan to ensure any required adjustments are made. FINANCIAL INSTITUTION SERVICES HIA provides investment advisory services, acting as a third-party manager, to certain broker/dealers’ customers (“Brokerage Customers”). These Brokerage Customers are referred to Highland by the broker/dealers and their solicitors. The Brokerage Customers enter into a written advisory agreement with HIA, similar to the advisory agreement for non- broker/dealer Customers. No additional fee to the client is charged as a result of the relationship between HIA and broker/dealers and/or HIA and the broker/dealers’ solicitors. Brokerage Customers receive a disclosure before or concurrent with signing an advisory agreement with HIA that describes the relationship between HIA and the broker/dealer and its solicitor. Please reference Section E under “Item 5 - Fees and Compensation” and Section G under “Item 10 - Other Financial Industry Activities and Affiliations” for more information related to this arrangement. PROFESSIONAL REIMBURSEMENT OPTION The professionals at Highland Investment Advisors are strong believers that we provide the greatest level of value to our clients by building a relationship that is based upon the confidence that only a strong financial plan can provide. In order for that plan to be successful, it must be based upon the most current and complete information, and very often requires the engagement of outside professionals who possess very specific skill sets. Effective collaboration with other professionals, most notably Certified Public Accountants, Enrolled Agents, and licensed Estate Planning Attorneys, gives us the greatest opportunity - 3 -  to craft a successful working plan. Based upon this need, and in a desire to encourage our clients to engage with the best independent professionals in this area, we have created the Professional Reimbursement Option (PRO) Plan. The PRO Plan allows you to hire the tax- or estate-planning professional of your choice, and within the terms of the Plan you will receive a management fee credit back from Highland for the professional service fees that you incur, up to a set limit amount. To benefit from this plan the following criteria must be met: The Accounting or Estate Planning profession that you retain must be practicing in good standing, and must be professionally credentialled with a Certified Public Accountant (CPA) or Enrolled Agent (EA) designation, or must be a member of the State Bar Association. The independent professional must be truly independent, must serve the client in a fiduciary capacity, and must not be in a position that could create conflicts of interest with regard to investment advice or commission-driven activities. This means that to qualify for PRO Plan reimbursement the professional may not possess any form of Securities Licensing, either through FINRA or the SEC, nor may they engage in the sale of insurance- related products. Additionally, the professional’s employing firm may not have any individuals on staff who are securities licensed or engaged in the sale of insurance products, nor may the firm have a common ownership or affiliation with another “outside firm” that engages in those activities. investment To participate in this program, Highland Investment Advisor must be the client’s sole investment/financial planning professional. While utilizing multiple professionals is always a client’s right, we have found that this arrangement is most valuable and effective for those individuals who utilize one primary advisor in each of their respective capacities. Certain types of investment accounts, such as employer-sponsored Retirement plans or self-directed trading accounts may be exempted, if Highland deems it to be in the best interest of the client. Because the purpose of this program is to encourage greater informational access and collaboration, in order to qualify for reimbursement under this plan the completed income tax return(s) or estate plan documents must be shared in full with a client’s advisor at Highland. In order for a client to receive the reimbursement amount for their professional services, their managed relationship with Highland must be in place for at least 90 days prior to the request for a credit. Credits are available on a calendar year basis, and unused benefits are not transferable from year-to-year. If the client qualifies for the PRO Plan, as outlined above, the following reimbursement credits would be available to them to offset or eliminate their income tax or estate planning costs. - 4 -  Assets Under Management Credit Available No credit available at this time Under $500,000 $500,000 to $1,000,000 $500.00 $1,000,001 to $2,500,000 $1,000.00 $2,500,001 to $5,000,000 $2,500.00 Over $5,000,000 $3,500.00 Client Tailored Services and Client Imposed Restrictions Wrap Fee Programs 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. Agreements may not be assigned without written Client consent. Client Assets under Management HIA does not sponsor any wrap fee programs. HIA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: $367,287,227 $980,633 Date Calculated: December 31, 2025 Item 5: Fees and Compensation Method of Compensation and Fee Schedule ASSET MANAGEMENT HIA offers direct asset management services to advisory Clients. HIA charges an annual Annualized Advisory Fee Schedule investment advisory fee based on the total assets under management as follows: Portfolio Size Annual Fee as % of Portfolio First $250,000 ($0 – $250,000) Next $2,250,000 ($250,001 - $2,500,000) 1.25% 1.00% Next $2,500,000 ($2,500,001 - $5,000,000) Above $5,000,000 Charitable/Non-profit Organizations 0.75% 0.50% 0.45% - 5 -  Portfolio Size Annual Fee as % of Portfolio First $250,000 ($0 – $250,000) Next $2,250,000 ($250,001 - $2,500,000) 1.25% 1.00% Next $2,500,000 ($2,500,001 - $5,000,000) 0.75% Above $5,000,000 Charitable/Non-profit Organizations 0.50% 0.45% 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 arrears based on an average daily balance of the account for the previous quarter. Additionally, this is a tiered/blended fee schedule, the asset management fee is calculated by applying different rates to different portions of the portfolio. HIA may group certain related Client accounts for the purposes of achieving the minimum account size and determining the annualized fee. The calculation for the average daily balance is based on the formula (A/D) x F. A = the sum of the daily balances in the billing period D = number of days in the billing period For example (based on quarterly billing period) F = quarterly management fee : the first step taken using the average- daily-balance calculation method would be to take the average of the values of the Client’s account over the course of the entire quarter. For instance 85 days at $1 million plus six days at $500,000 averages out to approximately $967,032. This account would be charged $2,573.83 for the quarter. Quarterly Fee Total AUM x .003125 = First $250,000 x .0025 = Next $717,032 Grand total for the quarter $781.25 $1,792.58 $2,573.83 HIA may also utilize the services of a Sub-Advisor to manage Clients’ investment portfolios. HIA will enter into Sub-Advisor agreements with other registered investment advisor firms. When using Sub-Advisors, the Client will not pay additional fees. The Sub-Advisors fees are inclusive of the total fee disclosed by HIA. 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 HIA with thirty (30) days written notice to Client and by the Client at any time with written notice to HIA. For accounts opened or closed mid- billing period, fees will be prorated based on the days services are provided during the given period. All unpaid earned fees will be due to HIA. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing - 6 -  by both parties before any increase in said fees occurs. ASSET HELD AWAY HIA offers discretionary direct asset management services to advisory Clients. HIA charges an annual investment advisory fee based on the total assets under management as follows: Portfolio Size Annual Fee as % of Portfolio First $250,000 ($0 – $250,000) Next $2,250,000 ($250,001 - $2,500,000) 1.25% 1.00% Next $2,500,000 ($2,500,001 - $5,000,000) 0.75% Above $5,000,000 Charitable/Non-profit Organizations 0.50% 0.45% The annual fee is negotiable. The Advisory Fee for the initial period will be paid on a pro rata basis based on the number of days in the billing period for which services under this Agreement were provided, in arrears, based on the billing period ending value of the Client’s managed assets, in accordance with the fee schedule listed in the Agreement. For all future periods, the Advisory Fee will be assessed and payable each billing period, in arrears, based on the balance of Client’s managed assets as of the prior period-end, in accordance with the fee schedule listed in the Agreement. By executing this Agreement, Client is authorizing HIA to debit its Advisory Fees directly from one or more of the Client’s Accounts. The Advisory Fee payable for any Held Away Account will be deducted directly from another Client Account, and if there are insufficient funds available in another Client Account or HIA believes that deducting the Advisory Fee from another Client Account would be prohibited by applicable law, it will invoice the Client. No fee adjustment will be made for Account deposits and withdrawals during a billing period. In addition to the fees paid to HIA, investments used in managing the Account may subject Client to additional fees. For example, mutual funds, index funds, exchange traded funds and private funds typically charge ongoing management fees and have other expenses for the operation of those funds. These fees should not be confused with “loads” or commissions. HIA does not receive any additional compensation, either directly or indirectly, from these investments. FINANCIAL PLANNING AND CONSULTING The professional fees for our Financial Planning and Consulting services generally range from $3,500 to $10,000, or more, depending on the scope and complexity of the engagement. Fees are based on factors such as the client’s marital status, number and type of investment accounts, other assets, etc. A retainer is required and is due upon execution of the Client Agreement. The remaining balance may be paid upon delivery of the financial plan, or through monthly or quarterly payments, as specified in the Client Agreement. All financial planning fees and billing arrangements are fully described in the Client Agreement. - 7 -  SUBSCRIPTION-BASED FINANICAL PLANNING Subscription-based financial planning is available for a fee starting at $175/month. Fees for financial plan billing are detailed in the Client Agreement. Client Payment of Fees FINANCIAL INSTITUTION SERVICES HIA receives a fee based on the Assets Under Management from Brokerage Customers who have provided written consent to a broker/dealer to receive the investment services from HIA and who have entered into a written advisory agreement with HIA. The fee is calculated from the Assets Under Management as of the end of a calendar quarter period multiplied by the annualized rate as specified in HIA’s advisory agreement with the Brokerage Customer. Fees charged to clients are shared between HIA and the broker/dealer per the solicitation agreement between HIA and the broker/dealer. The percentage of the fee shared between HIA and the broker/dealer and their solicitor may vary based on factors such as the size of the relationship or services rendered, but is generally split 70%/30% in favor of the broker/dealer. No additional fee to the client is charged as a result of the relationship between HIA and broker/dealers and/or HIA and the broker/dealers’ solicitors. Please reference Section E under “Item 4 – Advisory Business” and Section G under “Item 10 - Other Financial Industry Activities and Affiliations” for more information related to this arrangement. • 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 financial plans will be billed: • Deducted from a designated Client account. The Client must consent in advance to direct debiting of their investment account. Check – to be remitted by Client to HIA - 8 -  • • Deducted from a non-qualified account managed by HIA Additional Client Fees Charged Electronic Payment via ACH, Debit Card, or Credit Card (fees will be paid via a third party payment processor in which the client will securely input payment information and pay the advisory fee through a secure portal. HIA will not have continuous access to the Client’s banking information.) Prepayment of Client Fees 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. HIA does not receive any compensation from these fees. All of these fees are in addition to the management fee you pay to HIA. For more details on the brokerage practices, see Item 12 of this brochure. HIA does not require any prepayment of fees of more than $500 per Client and six months or more in advance. External Compensation for the Sale of Securities to Clients 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 HIA. Investment Advisor Representatives of HIA receive external compensation from sales of investment related products such as insurance as licensed insurance agents. This represents a conflict of interest because it gives an incentive to recommend products based on the commission received. This conflict is mitigated by disclosures, procedures, and HIA’s fiduciary obligation to place the best interest of the Client first and Clients are not required to purchase any products or services. Clients have the option to purchase these products through another insurance agent of their choosing. 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. HIA does not use a performance-based fee structure because of the conflict of interest. Performance based compensation may create an incentive for HIA to recommend an investment that may carry a higher degree of risk to the Client. Item 7: Types of Clients Description HIA generally provides investment advice to individuals, high net worth individuals, trusts, estates, or charitable organizations, and non-profits. Client relationships vary in scope and length of service. - 9 -  Account Minimums HIA requires a minimum of $500,000 to open an account. In certain instances, the minimum account size may be lowered or waived. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Investment advisory service begins with a thorough understanding of the client’s current situation, personal goals, and financial objectives. Information is gathered by means of personal interviews, risk assessment evaluations, and data gathering questionnaires. The data gathering process is collaborative. Clients are asked to thoroughly and candidly discuss or provide information on topics such as; their personal status, investment holdings, personal/family financial needs and goals, and their investment knowledge and experience. This in-depth information gathering process enables HIA to provide well- informed advice to clients. It also helps determine which services or investment style is appropriate for the client. Once the client’s investment objectives and investment risk tolerance are identified, a model portfolio is recommended to clients to assist them in achieving their investment objectives. The model portfolio may contain a mix of equity and debt securities with a view toward All investments entail some level of risk, the major sources of which are; market risk, achieving a particular rate of return in relation to an identified risk tolerance. interest rate risk, and inflation risk. While an attempt is made to minimize these risks through prudent investment strategies and portfolio design and construction, the risk of loss to the client is still present and real. No claims can be made, nor any guarantees offered for protection of clients against potential or actual loss. Clients are encouraged to discuss their evolving risk tolerance with HIA at any time. Investment Strategy HIA’s investment management philosophy is based on the concept of Functional Investing which rationalizes investments into three main categories or functions: 1. Growth, 2. Risk Reduction, and 3. Inflation Protection (GRIP). Each GRIP category incorporates investments which are consistent with that objective. For example, the Growth component primarily contains equity securities, Risk Reduction contains fixed income securities / alternative investments, and Inflation Protection may include commodities, real estate and inflation protected fixed income securities. The combination of the three GRIP components establishes the character and behavior of the constituent portfolio. HIA believes each of the GRIP components should have some representation in a portfolio. The proportions of each GRIP component depends upon the client’s risk aversion, return expectations, and other unique factors. - 10 -  Several other time-tested fundamental investment principles round out HIA’s investment philosophy. First, HIA believes in the general efficiency of the markets, but recognizes that they do not always behave rationally; Second, that there is a relationship between the rate of return that can be achieved and the amount of risk undertaken; and Third, that diversification among and within asset classes in order to manage risk is prudent. HIA’s model portfolios are created and managed using the current body of knowledge amassed from 50 years of academic investment and financial research and analysis, including the well-known “Modern Portfolio Theory” (“MPT”). According to MPT, a relationship exists between an asset class’s risk and its expected return. Successful investing means not only capturing risks that generate expected return but reducing risks that do not. Avoidable risks include holding too few securities, betting on countries or industries, following market predictions, and speculating on "information" from news shows, rating services, or internet investment tips. To all these, diversification is considered the antidote in that it washes away the random fortunes of individual stocks and positions in a portfolio to capture the returns of broad economic forces. In addition to established and new academic literature and studies, HIA utilizes fundamental analysis, investment periodicals, Morningstar, the internet and other sources of information to help us evaluate, refine and implement investment strategy and portfolio design. Model portfolios’ potential risk and expected return vary according to the weighting of the various GRIP components in each portfolio with a bias in favor of small capitalization equities and value-oriented equities. In general, the greater the proportion of stocks a portfolio holds, especially small cap and value stocks, the more "aggressive" is its risk and the greater is its expected return. Traditional active managers strive to beat the market by taking advantage of pricing "mistakes" and by attempting to predict the future. Too often, this proves costly and futile. HIA helps clients succeed at investing, not speculating. HIA’s management style thoroughly rejects the notion that additional return can be earned by predicting, or timing the markets. HIA focuses on designing and maintaining the optimal asset allocation consistent with the client’s objectives and risk tolerance. As a risk management technique, HIA may employ Hedging Strategies on a case-by-case basis. Because Hedging Strategies involve the use of stock options, only client accounts that have properly authorized option trading are eligible. Hedging Strategies may include selling “covered calls” or creating “option collars” and will be used for hedging purposes only, and not speculation. Hedging strategies will be used only for clients who have provided full consent by signing the Investment Management Agreement. In addition, HIA offers “Direct Indexing” strategies. Direct indexing is an investment approach that seeks to replicate the performance of a designated securities index by directly purchasing some or all of the individual equity securities comprising that index, rather than investing in a mutual fund or exchange-traded fund (“ETF”) that tracks the index. HIA constructs and manages customized portfolios designed to approximate the risk and return characteristics of a selected benchmark index (e.g., S&P 500, Russell 1000, or other broad or customized indices). Depending on account size, liquidity, and client-specific constraints, HIA may not purchase all securities in the index and instead may use optimization, sampling, or other portfolio construction techniques to seek similar exposure. - 11 -  . Security Specific Material Risks HIA attempts to minimize both direct and indirect portfolio costs and improve internal and external portfolio tax efficiency. HIA’s asset allocation strategy tends to require fewer securities transactions over time, clients’ commission expenses are lessened along with the likelihood that capital gains will be realized (with their potential tax consequences). Transactions will typically be performed when necessary to rebalance portfolios, allocate new investment dollars, make client requested redemptions, or alter a portfolio due to changing client investment objectives All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment • Market Risk risks and should discuss these risks with HIA: • : The prices of securities in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in Interest-rate Risk market value. • : Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, Inflation Risk causing their market values to decline. : When any type of inflation is present, a dollar today will buy more than a • Currency Risk dollar next year, because purchasing power is eroding at the rate of inflation. : 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 • Reinvestment Risk exchange rate risk. • Liquidity 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. • Management 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. • Equity 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. Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small- and mid- cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, - 12 -  • Fixed Income Risk: and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. • The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A nominal interest rate is the sum of a real interest Investment Companies Risk: rate and an expected inflation rate. • Foreign Securities Risk: When a client invests in open end mutual funds or ETFs, the client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which client invests. • Long-term purchases Funds in which clients invest may invest in foreign securities. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less publicly available information, limited trading markets and greater volatility. To the extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies. • Short-term purchases : Long-term investments are those vehicles purchased with the intention of being held for more than one year. Typically the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. : Short-term investments are typically held for one year or less. Generally there is not a high expectation for a return or an increase in value. Typically, short-term investments are purchased for the relatively greater degree of principal protection they are designed to provide. Short-term investment vehicles may be subject - 13 -  to purchasing power risk — the risk that your investment’s return will not keep up with • Trading risk inflation. : Investing involves risk, including possible loss of principal. There is no Direct Indexing Risk: assurance that the investment objective of any fund or investment will be achieved. • The portfolio may not closely track the performance of the selected index due to fees, transaction costs, cash flows, tax-related transactions, sampling techniques, or client- imposed restrictions. Tax-loss harvesting and other tax strategies may not produce the intended tax benefits and could result in higher transaction costs or unintended tax consequences. More frequent trading for rebalancing or tax management may increase brokerage costs and reduce returns.The risks associated with utilizing Sub-Advisors include: o Manager Risk • Sub-Advisor fails to execute the stated investment strategy o Business Risk • Sub-Advisor has financial or regulatory problems The specific risks associated with the portfolios of the Sub-Advisor’s which is disclosed in the Sub-Advisor’s Form ADV Part 2. Mutual funds from a variety of investment companies, including mutual funds from the Dimensional Fund Advisor (“DFA”) family of funds are used in constructing client portfolios. DFA funds are generally unavailable to investors either through direct purchase, normal mutual fund retail channels, or other financial intermediaries. DFA funds are generally available only to institutional investors and clients of select registered investment advisors. Due to DFA’s restricted distribution channel, clients who terminate their relationship with HIA and transfer their account(s) to another investment advisor and/or custodian, are encouraged to first discuss any possible limitations regarding the holding of their DFA investments with the successor custodian or new investment advisor. Clients who terminate their relationship with HIA and transfer their DFA assets may find their ability to hold, or purchase additional shares of DFA funds restricted or prohibited. If the successor custodian chosen by the transferring client cannot hold DFA fund(s), the client must identify an alternate custodian to accept and hold the client’s DFA fund(s). If no such arrangements are made, HIA may liquidate all DFA funds in the client account(s) and have the account custodian send the sales proceeds to the designated receiving broker- dealer, custodian or client. The liquidation transactions will result in the client paying transaction costs and may give rise to recognition of taxable capital gains or losses. Item 9: Disciplinary Information Criminal or Civil Actions Administrative Enforcement Proceedings HIA and its management have not been involved in any criminal or civil action. Self- Regulatory Organization Enforcement Proceedings HIA and its management have not been involved in administrative enforcement proceedings. HIA and its management have not been involved in any self-regulatory organizational - 14 -  enforcement proceedings that are material to a Client’s or prospective Client’s evaluation of HIA or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration HIA is not registered as a broker-dealer and no affiliated representatives of HIA are registered representatives of a broker-dealer. - 15 -  Futures or Commodity Registration Material Relationships Maintained by this Advisory Business and Conflicts of Interest Neither HIA nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. HIA has agreement(s) with broker/dealers to provide investment advisory services, acting as a third-party manager, to certain broker/dealers’ customers (“Brokerage Customers”). Fees charged to clients are shared between HIA and the broker/dealer per the solicitation agreement between HIA and the broker/dealer. This arrangement includes HIA assuming discretionary authority over Brokerage Customers’ brokerage accounts and the monitoring of securities. These consulting services offered to Brokerage Customers may include a general review of Brokerage Customers’ investment holdings, which may or may not result in HIA’s investment adviser representative making specific securities recommendations or offering general investment advice. Brokerage Customers will execute a written advisory agreement directly with HIA. No additional fee to the client is charged as a result of the relationship between HIA and broker/dealers and broker/dealer solicitors. This relationship presents conflicts of interest. Potential conflicts are mitigated by Brokerage Customers consenting to receive investment advisory services from HIA, by HIA not accepting or billing for additional compensation on broker/dealers’ Assets Under Management beyond the fees disclosed in Item 5 in connection with the investment advisory services, and by HIA not engaging as, or holding itself out to the public as, a securities broker/dealer. HIA is not affiliated with any broker/dealer. Please reference Section E under Recommendations or Selections of Other Investment Advisors and Conflicts of Interest “Item 4 – Advisory Business” for more information related to this arrangement. HIA may also utilize the services of a Sub-Advisor to manage Clients’ investment portfolios. Sub-Advisors will maintain the models or investment strategies agreed upon between Sub- Advisor and HIA. Sub-Advisors execute all trades on behalf of HIA in Client accounts. HIA will be responsible for the overall direct relationship with the Client. HIA retains the authority to terminate the Sub-Advisor relationship at HIA’s discretion. In addition to the authority granted to HIA, Clients will grant HIA full discretionary authority and authorizes HIA to select and appoint one or more independent investment advisors (“Advisors”) to provide investment advisory services to Client without prior consultation with or the prior consent of Client. Such Advisors shall have all of the same authority relating to the management of Client’s investment accounts as is granted to HIA in the Agreement. In addition, at HIA’s discretion, HIA may grant such Advisors full authority to further delegate such discretionary investment authority to additional Advisors. HIA ensures that before selecting other advisors for Client that the other advisors are properly licensed or registered as an investment advisor. This practice represents a conflict of interest as HIA may select Sub-Advisors who charge a lower fee for their services than other Sub-Advisors. This conflict is mitigated by disclosures, procedures, and by the fact that HIA has a fiduciary duty to place the best interest of the Client first and will adhere to their code of ethics. - 16 -  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description include employees and/or The affiliated persons (affiliated persons independent contractors) of HIA have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of HIA affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of HIA. The Code reflects HIA and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. HIA’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other affiliated person, officer or director of HIA 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. HIA’s Code is based on the guiding principle that the interests of the Client are our top priority. HIA’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non- public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. HIA 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 HIA and its affiliated persons do not recommend to Clients securities in which we have a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest HIA and its affiliated persons may buy or sell securities that are also held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide HIA with copies of their brokerage statements. The Chief Compliance Officer of HIA is Adam Drake. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of - 17 -  affiliated persons does not affect the markets and that Clients of the firm receive preferential Client Securities Recommendations or Trades and Concurrent Advisory Firm treatment over associated persons’ transactions. Securities Transactions and Conflicts of Interest HIA does not have a material financial interest in any securities being recommended. However, affiliated persons 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, affiliated persons are required to disclose all reportable securities transactions as well as provide HIA with copies of their brokerage statements. The Chief Compliance Officer of HIA is Adam Drake. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions HIA will recommend the use of a particular broker-dealer based on their duty to seek best execution for the client, meaning they have an obligation to obtain the most favorable terms for a client under the circumstances. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is affected, the ability to 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. HIA will select appropriate brokers based on a number of factors including but not limited to their relatively low transaction fees and reporting ability. HIA relies on its broker to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by HIA. HIA does not receive any portion of the trading fees. • Research and Other Soft Dollar Benefits HIA will recommend the use of Charles Schwab & Co., Inc. The Securities and Exchange Commission defines soft dollar practices as arrangement under which products or services other than execution services are obtained by HIA from or through a broker-dealer in exchange for directing Client transactions to the broker-dealer. Although HIA has no formal soft dollar arrangements, HIA may receive products, research and/or other services from custodians or broker-dealers connected to client transactions or “soft dollar benefits”. As permitted by Section 28(e) of the Securities Exchange Act of 1934, HIA receives economic benefits as a result of commissions generated from securities transactions by the custodian or broker-dealer from the accounts of HIA. HIA cannot ensure that a particular client will benefit from soft dollars or the client’s transactions paid for the soft dollar benefits. HIA does not seek to proportionately - 18 -  allocate benefits to client accounts to any soft dollar benefits generated by the accounts. • Brokerage for Client Referrals A conflict of interest exists when HIA receives soft dollars which could result in higher commissions charged to Clients. This conflict is mitigated by the fact that HIA has a fiduciary responsibility to act in the best interest of its Clients and the services received are beneficial to all Clients. • Directed Brokerage HIA does not receive client referrals from any custodian or third party in exchange for using that broker-dealer or third party. Aggregating Securities Transactions for Client Accounts Clients who direct brokerage outside our recommendation may be unable to achieve the most favorable execution of client transactions as client directed brokerage may cost clients more money. For example, in a directed brokerage account, you may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or you may receive less favorable prices. HIA 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 HIA. All Clients participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rated basis. If aggregation if not allowed or infeasible and individual transactions occur (e.g., withdrawal or liquidation requests, odd-lot trades, etc.) an account may potentially be assessed higher costs or less favorable prices than those where aggregation has occurred. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Account reviews are performed quarterly by the Chief Compliance Officer of HIA, Adam Drake. 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. Review of Client Accounts on Non-Periodic Basis Financial plans generated are updated as requested by the Client and pursuant to a new or amended agreement, HIA suggests updating at least annually. Content of Client Provided Reports and Frequency 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. Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by HIA’s custodian. Client receives confirmations of each transaction in account from custodian and an additional statement during any month in - 19 -  which a transaction occurs. Performance reports will be provided by HIA at least quarterly to Clients with assets under management Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest HIA presently has an arrangement with Calton & Associates, Inc., an SEC Registered Investment Advisor (“RIA”) located in Tampa, Florida, in which Calton’s solicitors refer clients to HIA. HIA verifies that the referring RIA firm and their Investment Advisor Representative’s (“IAR”) are properly registered by reviewing IARD/CRD data. In this referral arrangement, the client’s Advisory Fee is as follows: The fee schedule is lower than the one outlined in Item 5 – Fees because, in part, HIA doesn’t not provide financial planning services to these clients. HIA and the referring RIA firm share the fee, and no additional fees are paid by the client. Advisory Firm Payments for Client Referrals Such referral arrangements can create a conflict of interest in that both HIA and RIA have an interest in obtaining and securing the investment management relationship. HIA may enter into agreements with individuals and organizations, which may be affiliated or unaffiliated with HIA, that refer Clients to HIA in exchange for compensation. All such agreements will be in writing and comply with the requirements of Federal or State regulation. If a Client is introduced to HIA by a solicitor, HIA may pay that solicitor a fee. While the specific terms of each agreement may differ, generally, the compensation will be based upon HIA’s engagement of new Clients and is calculated using a varying percentage of the fees paid to HIA by such Clients. Any such fee shall be paid solely from HIA’s investment management fee, and shall not result in any additional charge to the Client. Each prospective Client who is referred to HIA under such an arrangement will receive a copy of this brochure and a separate written disclosure document disclosing the nature of the relationship between the solicitor and HIA and the amount of compensation that will be paid by HIA to the solicitor. The solicitor is required to obtain the Client’s signature acknowledging receipt of HIA’s disclosure brochure and the solicitor’s written disclosure statement. 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 carefully compare the account statements received directly from their custodians to any documentation or reports prepared by HIA. HIA is deemed to have limited custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of HIA. - 20 -  Item 16: Investment Discretion Discretionary Authority for Trading If applicable, Client will authorize HIA discretionary authority, via the advisory agreement, to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. If applicable, Client will authorize HIA discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. If however, consent for discretion is not given, HIA will obtain prior Client approval before executing each transaction. HIA allows Client’s to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. Such restrictions could include only allowing purchases of socially conscious investments. These restrictions must be provided to HIA in writing. The Client approves the custodian to be used and the commission rates paid to the custodian. HIA does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17: Voting Client Securities Proxy Votes HIA 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. When assistance on voting proxies is requested, HIA will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. If the Client requires assistance or has questions, they can reach out to the investment advisor representatives of the firm at the contact information on the cover page of this document. Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided to Clients because HIA does not serve as a custodian for Client funds or securities and HIA does not require prepayment of fees of more than $500 per Client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients Bankruptcy Petitions during the Past Ten Years HIA has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. HIA has not had any bankruptcy petitions in the last ten years. - 21 -  S U P E R V I S E D P E R S O N B R O C H U R E Item 1 Cover Page F O R M AD V P A R T 2B Adam Drake, CFA Main Office Address: 466 Town Plaza Ave, Suite 330 Ponte Vedra, FL 32081 WI Address: 414-755-2309 175 Patrick Blvd., Suite 120 Brookfield, WI 53045 Tel: Toll Free Tel: Fax: 877-755-2309 414-755-2313 Email: Website: adrake@highlandinvestmentadvisors.com www.highlandinvestmentadvisors.com February 16, 2026 This brochure supplement provides information about Adam Drake and supplements the Highland Investment Advisors, LLC brochure. You should have received a copy of that brochure. Please contact Adam Drake if you did not receive the brochure or if you have any questions about the contents of AD DI T IO N A L I N FO R MA T I ON A B OU T AD AM D R A K E (C R D # 3 2 3 4 1 1 5 ) I S this supplement. A V AI L AB L E O N T H E S EC ’ S W EB S I T E AT W W W . A DV I SE R I N F O . SE C . GO V . - 22 -  Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Principal Executive Officer – Adam Drake, CFA • Item 2 - Educational Background and Business Experience Year of birth: 1976 • Educational Background: University of Wisconsin - Milwaukee; Bachelor of Business Administration in Finance; 2000 Professional Certifications Adam Drake has earned certifications and credentials that are required to be explained in further detail. • Chartered Financial Analyst (CFA): Chartered Financial Analysts designation is awarded by the CFA Institute. CFA certification requirements: • • • • Hold a bachelor’s degree from an accredited institution or have equivalent educational or work experience. Successful completion of all three exam levels of the CFA Program. Have 48 months of acceptable professional work experience in the investment decision-making process. Fulfill society requirements, which vary by society. Unless you are upgrading from affiliate membership, all societies require two sponsor statements as part of each application; these are submitted online by your sponsors. Agree to adhere to and sign the Member's Agreement, a Professional Conduct Statement, and any additional documentation requested by CFA Institute. • Business Experience: • Highland Investment Advisors, LLC.; Managing Member/Investment Advisor Representative; 01/2009-Present • Vogel Consulting; Investment Analyst; 08/2008-04/2010 • McSherry & Associates; Portfolio Manager; 07/2005-08/2008 • Capital Financial Services, Inc.; Registered Representative; 07/2005-08/2008 Item 3 - Disciplinary Information Robert W Baird & Co; Research Analyst; 07/2003-07/2005 1. Mr. Drake has never been involved in a criminal or civil action in a domestic, foreign or military court of competent jurisdiction for which he: a. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony; (b) misdemeanor that involved investments or an investment-related business, fraud, false statement or omissions, wrongful taking of property, bribery, perjury, counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses; - 23 -  b. c. d. Is the named subject of a pending criminal proceeding that involves an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses; Was found to have been involved in a violation of an investment-related statute or regulation; or Was the subject of any order, judgement or decree permanently or temporarily enjoining, or otherwise limiting, him from engaging in any investment related activity, or from violating any investment-related statute, rule, or order. 2. Mr. Drake never had an administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which he: a. b. Was found to have caused an investment-related business to lose its authorization to do business; or the subject of an order by the agency or authority; Was found to have been involved in a violation of an investment-related statute or regulation or was the subject of an order by the agency or authority a. (a)denying, suspending or revoking the authorization of the supervised person to act in an investment-related business; (b) barring or suspending his association with an investment-related business; (c) otherwise significantly limiting his investment-related activities; or (d) imposing a civil money penalty of more than $2,500 on him. 3. Mr. Drake has never been the subject of a self-regulatory organization (SRO) proceeding in which he: a. b. Was found to have caused an investment-related business to lose its authorization to do business; or Was found to have been involved in a violation of the SRO’s rules and was: (a) barred or suspended from membership or from association with other members, or was expelled from membership; (b) otherwise significantly limited from investment-related activities; or (c) fined more than $2,500. 4. Item 4 - Other Business Activities Mr. Drake has not been involved in any other hearing or formal adjudication in which a professional attainment, designation, or license of the supervised person was revoked or suspended because of a violation of rules relating to professional conduct. Item 5 - Additional Compensation Mr. Drake does not engage in any outside business activities. Item 6 - Supervision Mr. Drake does not receive any performance-based fees and does not receive any additional compensation for performing advisory services other than what is disclosed in Item 5 of Part 2A. Mr. Drake is the Chief Compliance Officer of HIA and as such he is solely responsible for all supervision and formulation and monitoring of investment advice offered to Clients. He will adhere to the policies and procedures as described in the firm’s Compliance Manual. He can be reached at adrake@highlandinvestmnetadvisors.com or 414-755-2309. - 24 - 

F O R M A D V P A R T 2 A D I S C L O S U R E B R O C H U R E Main Office Address: 466 Town Plaza Ave, Suite 330 Ponte Vedra, FL 32081 WI Address: 175 Patrick Blvd., Suite 120 Brookfield, WI 53045 Tel: 414-755-2309 Toll Free Tel: 877-755-2309 Fax: 414-755-2313 Email: adrake@highlandinvestmentadvisors.com Website: www.highlandinvestmentadvisors.com February 16, 2026 This brochure provides information about the qualifications and business practices of Highland Investment Advisors, LLC. Being registered as an 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 414-755-2309. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. A D D I T I O N A L I N F O R M A T I O N A B O U T H I G H L A N D I N V E S T M E N T A D V I S O R S , L L C ( C R D # 1 4 1 6 9 4 ) I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V  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 filing on February 26, 2025, the following material changes have occurred: • Item 4 has been updated to disclose the most recent calculation for assets under management calculation. • Item 5 has been updated to disclose current fees for financial planning. • Item 8 has been updated to add disclosures for direct indexing. Full Brochure Available This Firm Brochure being delivered is the complete brochure for the Firm.  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 ..................................................................................................................................................... 8 Additional Client Fees Charged .................................................................................................................................... 8 Prepayment of Client Fees .............................................................................................................................................. 8 External Compensation for the Sale of Securities to Clients............................................................................ 8 Item 6: Performance-Based Fees and Side-by-Side Management ..................................... 9 Sharing of Capital Gains ................................................................................................................................................... 9 Item 7: Types of Clients .............................................................................................................. 9 Description ............................................................................................................................................................................ 9 Account Minimums ............................................................................................................................................................ 9 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .............................. 9 Methods of Analysis........................................................................................................................................................... 9 Investment Strategy .......................................................................................................................................................... 9 Security Specific Material Risks................................................................................................................................. 11 Item 9: Disciplinary Information .......................................................................................... 14 Criminal or Civil Actions ............................................................................................................................................... 14 Administrative Enforcement Proceedings............................................................................................................ 14 Self- Regulatory Organization Enforcement Proceedings ............................................................................. 14  Item 10: Other Financial Industry Activities and Affiliations ......................................... 14 Broker-Dealer or Representative Registration .................................................................................................. 14 Futures or Commodity Registration........................................................................................................................ 14 Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................ 14 Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ............. 15 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ....................................................................................................................................... 15 Code of Ethics Description........................................................................................................................................... 15 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 16 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 16 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest.................................................................................................................... 16 Item 12: Brokerage Practices ................................................................................................ 16 Factors Used to Select Broker-Dealers for Client Transactions .................................................................. 16 Aggregating Securities Transactions for Client Accounts .............................................................................. 17 Item 13: Review of Accounts .................................................................................................. 18 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ............................................................................................................................................................................... 18 Review of Client Accounts on Non-Periodic Basis ............................................................................................ 18 Content of Client Provided Reports and Frequency ......................................................................................... 18 Item 14: Client Referrals and Other Compensation .......................................................... 18 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ................................................................................................................................................................................. 18 Advisory Firm Payments for Client Referrals ..................................................................................................... 18 Item 15: Custody....................................................................................................................... 19 Account Statements ........................................................................................................................................................ 19 Item 16: Investment Discretion ............................................................................................ 19 Discretionary Authority for Trading ....................................................................................................................... 19 Item 17: Voting Client Securities........................................................................................... 19 Proxy Votes......................................................................................................................................................................... 19 Item 18: Financial Information ............................................................................................. 20 Balance Sheet..................................................................................................................................................................... 20 Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients .............................................................................................................................................................................. 20 Bankruptcy Petitions during the Past Ten Years ............................................................................................... 20  Principal Executive Officer – Adam Drake, CFA ................................................................................................. 22 Item 2 - Educational Background and Business Experience ........................................................................ 22 Item 3 - Disciplinary Information ............................................................................................................................. 22 Item 4 - Other Business Activities ............................................................................................................................ 23 Item 5 - Additional Compensation ........................................................................................................................... 23 Item 6 - Supervision........................................................................................................................................................ 23  Item 4: Advisory Business Firm Description Highland Investment Advisors, LLC (“HIA”) was founded in 2006. Adam Drake is 100% owner. Highland Investment Advisors LLC provides investment advice under Highland Investment Advisors LLC (“HIA), Highland Investment Advisors LLC DBA Fund Management (“FM”), and Highland Investment Advisors LLC DBA Whitman Wealth Management (“WWM”). Fund Management (“FM”) and Whitman Wealth Management have separate ADVs, available upon request or on our website. Types of Advisory Services ASSET MANAGEMENT HIA offers discretionary and non-discretionary asset management services to advisory Clients. HIA 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. Discretionary When the Client provides HIA discretionary authority the Client will sign a limited trading authorization or equivalent. HIA 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 HIA on a non-discretionary basis, HIA will determine the securities to be bought or sold and the amount of the securities to be bought or sold. However, HIA will obtain prior Client approval on each and every transaction before executing any transaction. When deemed appropriate for the Client, HIA may hire Sub-Advisors to manage all or a portion of the assets in the Client account. HIA has full discretion to hire and fire Sub- Advisors as they deem suitable. Sub-Advisors will maintain the models or investment strategies agreed upon between Sub-Advisor and HIA. Sub-Advisors execute trades on behalf of HIA in Client accounts. HIA will be responsible for the overall direct relationship with the Client. HIA retains the authority to terminate the Sub-Advisor relationship at HIA’s discretion. HIA is an authorized provider of Dimensional Fund Advisor (“DFA”) mutual funds and may purchase and hold DFA funds in client portfolios. DFA funds are generally not available through retail investment channels. This restriction may limit a client’s ability to manage these funds should the client subsequently terminate his/her relationship with HIA . As part of the recommendations provided, the Client may have a financial plan completed. This may include but is not limited to a thorough review of all applicable topics such as Investments, Taxes, Qualified Plans, Insurance, Retirement Income, College Planning, Home Buying, Budgeting, Debt Management, Emergency Funds, and Risk Tolerance Assessment. If a conflict of interest exists between the interests of HIA and the interests of the Client, the Client is under no obligation to act upon HIA’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through HIA. This service will be provided at no additional cost to the Client. - 1 -  ASSETS HELD AWAY HIA uses a third party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive 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 Client account(s) is connected to the platform, HIA will review the current account allocations. When deemed necessary, HIA will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. FINANCIAL PLANNING AND CONSULTING Financial planning services include a comprehensive evaluation of an investor'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. HIA will use current net worth, tax liabilities, asset allocation, and future retirement and estate plans in developing financial plans. Typical topics reviewed in a financial plan may include but are not limited to: • Financial goals: Based on an individual's or a family's clearly defined financial goals, including funding a college education for the children, buying a larger home, starting a business, retiring on time or leaving a legacy. Financial goals should be quantified and set to milestones for tracking. • 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. • Comprehensive risk management plan: Identify all risk exposures and provide the necessary coverage to protect the family and its assets against financial loss. The risk management plan includes a full review of life and disability insurance, personal liability coverage, property and casualty coverage, and catastrophic coverage. for selecting, buying and selling • Long-term investment plan: Include a customized asset allocation strategy based on specific investment objectives and a risk profile. This investment plan sets guidelines 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. - 2 -  • 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 HIA and the interests of the Client, the Client is under no obligation to act upon HIA’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through HIA. Financial plans will be completed and delivered inside of ninety (90) days contingent upon timely delivery of all required documentation. SUBSCRIPTION-BASED FINANICAL PLANNING This service involves working one-on-one with Beverly over an extended period of time. By paying the monthly fee, Clients will work with Beverly to identify and prioritize goals and develop and implement their financial plan. Upon desiring a comprehensive plan, a Client will be taken through a four or five-meeting process over two or three months to assist them in establishing their goals and values around money. They will be required to provide information to help complete the following areas of analysis: net worth, cash flow, insurance, employee benefits, retirement planning, insurance, investments, college planning, and estate planning. Once the Client's information is reviewed and data is compiled, a draft will be reviewed with the Client. Clients Point A (where they are now) is established. Once the draft is reviewed with the client, a final meeting is scheduled to address how to reach their goals or their Point B (where they are going). Clients subscribing to this service will receive a written or an electronic report, providing the Client with a detailed financial plan designed to work towards Clients’ stated financial goals and objectives. This report will include at a minimum a Net Worth Statement, ten years of cash flow statements, a Monte Carlo analysis, and recommendations. If a follow-up meeting is required, we will meet at the Client's convenience. While the implementation of the plan is solely the client’s responsibility, Beverly is available for assistance or as questions arise. On an annual basis, clients are invited for a full review of this plan to ensure any required adjustments are made. FINANCIAL INSTITUTION SERVICES HIA provides investment advisory services, acting as a third-party manager, to certain broker/dealers’ customers (“Brokerage Customers”). These Brokerage Customers are referred to Highland by the broker/dealers and their referring parties. The Brokerage Customers enter into a written advisory agreement with HIA, similar to the advisory agreement for non-broker/dealer Customers. No additional fee to the client is charged as a result of the relationship between HIA and broker/dealers and/or HIA and the broker/dealers’ referring parties. Brokerage Customers receive a disclosure before or concurrent with signing an advisory agreement with HIA that describes the relationship between HIA and the broker/dealer and its referring party. Please reference Section E under “Item 5 - Fees and Compensation” and Section G under “Item 10 - Other Financial Industry Activities and Affiliations” for more information related to this arrangement. PROFESSIONAL REIMBURSEMENT OPTION The professionals at Highland Investment Advisors are strong believers that we provide the greatest level of value to our clients by building a relationship that is based upon the confidence that only a strong financial plan can provide. In order for that plan to be - 3 -  successful, it must be based upon the most current and complete information, and very often requires the engagement of outside professionals who possess very specific skill sets. Effective collaboration with other professionals, most notably Certified Public Accountants, Enrolled Agents, and licensed Estate Planning Attorneys, gives us the greatest opportunity to craft a successful working plan. Based upon this need, and in a desire to encourage our clients to engage with the best independent professionals in this area, we have created the Professional Reimbursement Option (PRO) Plan. The PRO Plan allows you to hire the tax- or estate-planning professional of your choice, and within the terms of the Plan you will receive a management fee credit back from Highland for the professional service fees that you incur, up to a set limit amount. To benefit from this plan the following criteria must be met: The Accounting or Estate Planning profession that you retain must be practicing in good standing, and must be professionally credentialled with a Certified Public Accountant (CPA) or Enrolled Agent (EA) designation, or must be a member of the State Bar Association. The independent professional must be truly independent, must serve the client in a fiduciary capacity, and must not be in a position that could create conflicts of interest with regard to investment advice or commission-driven activities. This means that to qualify for PRO Plan reimbursement the professional may not possess any form of Securities Licensing, either through FINRA or the SEC, nor may they engage in the sale of insurance- related products. Additionally, the professional’s employing firm may not have any individuals on staff who are securities licensed or engaged in the sale of insurance products, nor may the firm have a common ownership or affiliation with another “outside firm” that engages in those activities. To participate in this program, Highland Investment Advisor must be the client’s sole investment/financial planning professional. While utilizing multiple investment professionals is always a client’s right, we have found that this arrangement is most valuable and effective for those individuals who utilize one primary advisor in each of their respective capacities. Certain types of investment accounts, such as employer-sponsored Retirement plans or self-directed trading accounts may be exempted, if Highland deems it to be in the best interest of the client. Because the purpose of this program is to encourage greater informational access and collaboration, in order to qualify for reimbursement under this plan the completed income tax return(s) or estate plan documents must be shared in full with a client’s advisor at Highland. In order for a client to receive the reimbursement amount for their professional services, their managed relationship with Highland must be in place for at least 90 days prior to the request for a credit. Credits are available on a calendar year basis, and unused benefits are not transferable from year-to-year. If the client qualifies for the PRO Plan, as outlined above, the following reimbursement credits would be available to them to offset or eliminate their income tax or estate planning costs. - 4 -  Assets Under Management Credit Available Under $500,000 No credit available at this time $500,000 to $1,000,000 $500.00 $1,000,001 to $2,500,000 $1,000.00 $2,500,001 to $5,000,000 $2,500.00 Over $5,000,000 $3,500.00 Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. Wrap Fee Programs HIA does not sponsor any wrap fee programs. Client Assets under Management HIA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: $367,287,227 $980,633 Date Calculated: December 31, 2025 Item 5: Fees and Compensation Method of Compensation and Fee Schedule ASSET MANAGEMENT HIA offers direct asset management services to advisory Clients. HIA charges an annual investment advisory fee based on the total assets under management as follows: Annualized Advisory Fee Schedule Annual Fee as % of Portfolio Portfolio Size First $250,000 ($0 – $250,000) Next $2,250,000 ($250,001 - $2,500,000) 1.25% 1.00% Next $2,500,000 ($2,500,001 - $5,000,000) 0.75% Above $5,000,000 Charitable/Non-profit Organizations 0.50% 0.45% - 5 -  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, negotiation s with Clients, etc.). Fees are billed quarterly in arrears based on an average daily balance of the account for the previous quarter. Additionally, this is a tiered/blended fee schedule, the asset management fee is calculated by applying different rates to different portions of the portfolio. HIA may group certain related Client accounts for the purposes of achieving the minimum account size and determining the annualized fee. The calculation for the average daily balance is based on the formula (A/D) x F. A = the sum of the daily balances in the billing period D = number of days in the billing period F = quarterly management fee For example (based on quarterly billing period): the first step taken using the average- daily-balance calculation method would be to take the average of the values of the Client’s account over the course of the entire quarter. For instance 85 days at $1 million plus six days at $500,000 averages out to approximately $967,032. This account would be charged $2,573.83 for the quarter. Quarterly Fee Total AUM x .003125 = First $250,000 Next $717,032 x .0025 = Grand total for the quarter $781.25 $1,792.58 $2,573.83 HIA may also utilize the services of a Sub-Advisor to manage Clients’ investment portfolios. HIA will enter into Sub-Advisor agreements with other registered investment advisor firms. When using Sub-Advisors, the Client will not pay additional fees. The Sub-Advisors fees are inclusive of the total fee disclosed by HIA. 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 HIA with thirty (30) days written notice to Client and by the Client at any time with written notice to HIA. For accounts opened or closed mid- billing period, fees will be prorated based on the days services are provided during the given period. All unpaid earned fees will be due to HIA. 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. ASSET HELD AWAY HIA offers discretionary direct asset management services to advisory Clients. HIA charges an annual investment advisory fee based on the total assets under management as follows: Annual Fee as % of Portfolio Portfolio Size First $250,000 ($0 – $250,000) Next $2,250,000 ($250,001 - $2,500,000) 1.25% 1.00% Next $2,500,000 ($2,500,001 - $5,000,000) 0.75% - 6 -  Above $5,000,000 Charitable/Non-profit Organizations 0.50% 0.45% The annual fee is negotiable. The Advisory Fee for the initial period will be paid on a pro rata basis based on the number of days in the billing period for which services under this Agreement were provided, in arrears, based on the billing period ending value of the Client’s managed assets, in accordance with the fee schedule listed in the Agreement. For all future periods, the Advisory Fee will be assessed and payable each billing period, in arrears, based on the balance of Client’s managed assets as of the prior period -end, in accordance with the fee schedule listed in the Agreement. By executing this Agreement, Client is authorizing HIA to debit its Advisory Fees directly from one or more of the Client’s Accounts. The Advisory Fee payable for any Held Away Account will be deducted directly from another Client Account, and if there are insufficient funds available in another Client Account or HIA believes that deducting the Advisory Fee from another Client Account would be prohibited by applicable law, it will invoice the Client. No fee adjustment will be made for Account deposits and withdrawals during a billing period. In addition to the fees paid to HIA, investments used in managing the Account may subject Client to additional fees. For example, mutual funds, index funds, exchange traded funds and private funds typically charge ongoing management fees and have other expenses for the operation of those funds. These fees should not be confused with “loads” or commissions. HIA does not receive any additional compensation, either directly or indirectly, from these investments. FINANCIAL PLANNING AND CONSULTING The professional fees for our Financial Planning and Consulting services generally range from $3,500 to $10,000, or more, depending on the scope and complexity of the engagement. Fees are based on factors such as the client’s marital status, number and type of investment accounts, other assets, etc. A retainer is required and is due upon execution of the Client Agreement. The remaining balance may be paid upon delivery of the financial plan, or through monthly or quarterly payments, as specified in the Client Agreement. All financial planning fees and billing arrangements are fully described in the Client Agreement. SUBSCRIPTION-BASED FINANICAL PLANNING Subscription-based financial planning is available for a fee starting at $175/month. Fees for financial plan billing are detailed in the Client Agreement. FINANCIAL INSTITUTION SERVICES HIA receives a fee based on the Assets Under Management from Brokerage Customers who have provided written consent to a broker/dealer to receive the investment services from HIA and who have entered into a written advisory agreement with HIA. The fee is calculated from the Assets Under Management as of the end of a calendar quarter period multiplied by the annualized rate as specified in HIA’s advisory agreement with the Brokerage Customer. Fees charged to clients are shared between HIA and the broker/dealer per the referral agreement between HIA and the broker/dealer. The percentage of the fee shared between HIA and the broker/dealer and their referring party - 7 -  may vary based on factors such as the size of the relationship or services rendered, but is generally split 70%/30% in favor of the broker/dealer. No additional fee to the client is charged as a result of the relationship between HIA and broker/dealers and/or HIA and the broker/dealers’ referring party. Please reference Section E under “Item 4 – Advisory Business” and Section G under “Item 10 - Other Financial Industry Activities and Affiliations” for more information related to this arrangement. 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 financial plans will be billed: • Deducted from a designated Client account. The Client must consent in advance to direct debiting of their investment account. • Check – to be remitted by Client to HIA • Deducted from a non-qualified account managed by HIA • Electronic Payment via ACH, Debit Card, or Credit Card (fees will be paid via a third party payment processor in which the client will securely input payment information and pay the advisory fee through a secure portal. HIA will not have continuous access to the Client’s banking information.) 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. HIA does not receive any compensation from these fees. All of these fees are in addition to the management fee you pay to HIA. For more details on the brokerage practices, see Item 12 of this brochure. Prepayment of Client Fees HIA does not require any prepayment of fees of more than $500 per Client and six months or more in advance. 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 HIA. External Compensation for the Sale of Securities to Clients Investment Advisor Representatives of HIA receive external compensation from sales of investment related products such as insurance as licensed insurance agents. This represents a conflict of interest because it gives an incentive to recommend products based on the commission received. This conflict is mitigated by disclosures, procedures, and HIA’s fiduciary obligation to place the best interest of the Client first and Clients are not required to purchase any products or services. Clients have the option to purchase these products through another insurance agent of their choosing. - 8 -  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. HIA does not use a performance-based fee structure because of the conflict of interest. Performance based compensation may create an incentive for HIA to recommend an investment that may carry a higher degree of risk to the Client. Item 7: Types of Clients Description HIA generally provides investment advice to individuals, high net worth individuals, trusts, estates, or charitable organizations, and non-profits. Client relationships vary in scope and length of service. Account Minimums HIA requires a minimum of $500,000 to open an account. In certain instances, the minimum account size may be lowered or waived. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Investment advisory service begins with a thorough understanding of the client’s current situation, personal goals, and financial objectives. Information is gathered by means of personal interviews, risk assessment evaluations, and data gathering questionnaires. The data gathering process is collaborative. Clients are asked to thoroughly and candidly discuss or provide information on topics such as; their personal status, investment holdings, personal/family financial needs and goals, and their investment knowledge and experience. This in-depth information gathering process enables HIA to provide well- informed advice to clients. It also helps determine which services or investment style is appropriate for the client.Once the client’s investment objectives and investment risk tolerance are identified, a model portfolio is recommended to clients to assist them in achieving their investment objectives. The model portfolio may contain a mix of equity and debt securities with a view toward achieving a particular rate of return in relation to an identified risk tolerance. All investments entail some level of risk, the major sources of which are; market risk, interest rate risk, and inflation risk. While an attempt is made to minimize these risks through prudent investment strategies and portfolio design and construction, the risk of loss to the client is still present and real. No claims can be made, nor any guarantees offered for protection of clients against potential or actual loss. Clients are encouraged to discuss their evolving risk tolerance with HIA at any time. Investment Strategy HIA’s investment management philosophy is based on the concept of Functional Investing which rationalizes investments into three main categories or functions: 1. Growth, - 9 -  2. Risk Reduction, and 3. Inflation Protection (GRIP). Each GRIP category incorporates investments which are consistent with that objective. For example, the Growth component primarily contains equity securities, Risk Reduction contains fixed income securities / alternative investments, and Inflation Protection may include commodities, real estate and inflation protected fixed income securities. The combination of the three GRIP components establishes the character and behavior of the constituent portfolio. HIA believes each of the GRIP components should have some representation in a portfolio. The proportions of each GRIP component depends upon the client’s risk aversion, return expectations, and other unique factors. Several other time-tested fundamental investment principles round out HIA’s investment philosophy. First, HIA believes in the general efficiency of the markets, but recognizes that they do not always behave rationally; Second, that there is a relationship between the rate of return that can be achieved and the amount of risk undertaken; and Third, that diversification among and within asset classes in order to manage risk is prudent. HIA’s model portfolios are created and managed using the current body of knowledge amassed from 50 years of academic investment and financial research and analysis, including the well-known “Modern Portfolio Theory” (“MPT”). According to MPT, a relationship exists between an asset class’s risk and its expected return. Successful investing means not only capturing risks that generate expected return but reducing risks that do not. Avoidable risks include holding too few securities, betting on countries or industries, following market predictions, and speculating on "information" from news shows, rating services, or internet investment tips. To all these, diversification is considered the antidote in that it washes away the random fortunes of individual stocks and positions in a portfolio to capture the returns of broad economic forces. In addition to established and new academic literature and studies, HIA utilizes fundamental analysis, investment periodicals, Morningstar, the internet and other sources of information to help us evaluate, refine and implement investment strategy and portfolio design. Model portfolios’ potential risk and expected return vary according to the weighting of the various GRIP components in each portfolio with a bias in favor of small capitalization equities and value-oriented equities. In general, the greater the proportion of stocks a portfolio holds, especially small cap and value stocks, the more "aggressive" is its risk and the greater is its expected return. Traditional active managers strive to beat the market by taking advantage of pricing "mistakes" and by attempting to predict the future. Too often, this proves costly and futile. HIA helps clients succeed at investing, not speculating. HIA’s management style thoroughly rejects the notion that additional return can be earned by predicting, or timing the markets. HIA focuses on designing and maintaining the optimal asset allocation consistent with the client’s objectives and risk tolerance. As a risk management technique, HIA may employ Hedging Strategies on a case-by-case basis. Because Hedging Strategies involve the use of stock options, only client accounts that have properly authorized option trading are eligible. Hedging Strategies may include - 10 -  selling “covered calls” or creating “option collars” and will be used for hedging purposes only, and not speculation. Hedging strategies will be used only for clients who have provided full consent by signing the Investment Management Agreement. In addition, HIA offers “Direct Indexing” strategies. Direct indexing is an investment approach that seeks to replicate the performance of a designated securities index by directly purchasing some or all of the individual equity securities comprising that index, rather than investing in a mutual fund or exchange-traded fund (“ETF”) that tracks the index. HIA constructs and manages customized portfolios designed to approximate the risk and return characteristics of a selected benchmark index (e.g., S&P 500, Russell 1000, or other broad or customized indices). Depending on account size, liquidity, and client-specific constraints, HIA may not purchase all securities in the index and instead may use optimization, sampling, or other portfolio construction techniques to seek similar exposure. HIA attempts to minimize both direct and indirect portfolio costs and improve internal and external portfolio tax efficiency. HIA’s asset allocation strategy tends to require fewer securities transactions over time, clients’ commission expenses are lessened along with the likelihood that capital gains will be realized (with their potential tax consequences). Transactions will typically be performed when necessary to rebalance portfolios, allocate new investment dollars, make client requested redemptions, or alter a portfolio due to changing client investment objectives. Security Specific Material Risks All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks and should discuss these risks with HIA: • Market Risk: The prices of securities in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. • 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. - 11 -  • 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. • Equity Risk: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small- and mid- cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. • Fixed Income Risk: The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. • Investment Companies Risk: When a client invests in open end mutual funds or ETFs, the client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which client invests. • Foreign Securities Risk: Funds in which clients invest may invest in foreign securities. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less publicly available information, limited trading markets and greater volatility. To the extent that underlying funds invest in - 12 -  issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies. • Long-term purchases: Long-term investments are those vehicles purchased with the intention of being held for more than one year. Typically the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. • Short-term purchases: Short-term investments are typically held for one year or less. Generally there is not a high expectation for a return or an increase in value. Typically, short-term investments are purchased for the relatively greater degree of principal protection they are designed to provide. Short-term investment vehicles may be subject to purchasing power risk — the risk that your investment’s return will not keep up with inflation. • Trading risk: Investing involves risk, including possible loss of principal. There is no assurance that the investment objective of any fund or investment will be achieved. • Direct Indexing Risk: The portfolio may not closely track the performance of the selected index due to fees, transaction costs, cash flows, tax-related transactions, sampling techniques, or client-imposed restrictions. Tax-loss harvesting and other tax strategies may not produce the intended tax benefits and could result in higher transaction costs or unintended tax consequences. More frequent trading for rebalancing or tax management may increase brokerage costs and reduce returns. The risks associated with utilizing Sub-Advisors include: • Manager Risk o Sub-Advisor fails to execute the stated investment strategy • Business Risk o Sub-Advisor has financial or regulatory problems • The specific risks associated with the portfolios of the Sub -Advisor’s which is disclosed in the Sub-Advisor’s Form ADV Part 2. Mutual funds from a variety of investment companies, including mutual funds from the Dimensional Fund Advisor (“DFA”) family of funds are used in constructing client portfolios. DFA funds are generally unavailable to investors either through direct purchase, normal mutual fund retail channels, or other financial intermediaries. DFA funds are generally available only to institutional investors and clients of select registered investment advisors. Due to DFA’s restricted distribution channel, clients who terminate their relationship with HIA and transfer their account(s) to another investment advisor and/or custodian, are encouraged to first discuss any possible limitations regarding the holding of their DFA investments with the successor custodian or new investment advisor. Clients who - 13 -  terminate their relationship with HIA and transfer their DFA assets may find their ability to hold, or purchase additional shares of DFA funds restricted or prohibited. If the successor custodian chosen by the transferring client cannot hold DFA fund(s), the client must identify an alternate custodian to accept and hold the client’s DFA fund(s). If no such arrangements are made, HIA may liquidate all DFA funds in the client account(s) and have the account custodian send the sales proceeds to the designated receiving broker - dealer, custodian or client. The liquidation transactions will result in the client paying transaction costs and may give rise to recognition of taxable capital gains or losses. Item 9: Disciplinary Information Criminal or Civil Actions HIA and its management have not been involved in any criminal or civil action. Administrative Enforcement Proceedings HIA and its management have not been involved in administrative enforcement proceedings. Self- Regulatory Organization Enforcement Proceedings HIA and its management have not been involved in any self-regulatory organizational enforcement proceedings that are material to a Client’s or prospective Client’s evaluation of HIA or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration HIA is not registered as a broker-dealer and no affiliated representatives of HIA are registered representatives of a broker-dealer. Futures or Commodity Registration Neither HIA nor its affiliated representatives are registered or have 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 HIA has agreement(s) with broker/dealers to provide investment advisory services, acting as a third-party manager, to certain broker/dealers’ customers (“Brokerage Customers”). Fees charged to clients are shared between HIA and the broker/dealer per the referral agreement between HIA and the broker/dealer. This arrangement includes HIA assuming discretionary authority over Brokerage Customers’ brokerage accounts and the monitoring of securities. These consulting services offered to Brokerage Customers may include a general review of Brokerage Customers’ investment holdings, which may or may not result in HIA’s investment adviser representative making specific securities recommendations or offering general investment advice. Brokerage Customers will execute a written advisory agreement directly with HIA. No additional fee to the client is charged as a result of the relationship between HIA and broker/dealers and broker/dealer referring parties. This relationship presents conflicts of interest. Potential conflicts are mitigated by Brokerage Customers consenting to receive investment advisory services from HIA, by HIA not accepting or billing for additional compensation on broker/dealers’ Assets Under - 14 -  Management beyond the fees disclosed in Item 5 in connection with the investment advisory services, and by HIA not engaging as, or holding itself out to the public as, a securities broker/dealer. HIA is not affiliated with any broker/dealer. Please reference Section E under “Item 4 – Advisory Business” for more information related to this arrangement. Recommendations or Selections of Other Investment Advisors and Conflicts of Interest HIA may also utilize the services of a Sub-Advisor to manage Clients’ investment portfolios. Sub-Advisors will maintain the models or investment strategies agreed upon between Sub- Advisor and HIA. Sub-Advisors execute all trades on behalf of HIA in Client accounts. HIA will be responsible for the overall direct relationship with the Client. HIA retains the authority to terminate the Sub-Advisor relationship at HIA’s discretion. In addition to the authority granted to HIA, Clients will grant HIA full discretionary authority and authorizes HIA to select and appoint one or more independent investment advisors (“Advisors”) to provide investment advisory services to Client without prior consultation with or the prior consent of Client. Such Advisors shall have all of the same authority relating to the management of Client’s investment accounts as is granted to HIA in the Agreement. In addition, at HIA’s discretion, HIA may grant such Advisors full authority to further delegate such discretionary investment authority to additional Advisors. HIA ensures that before selecting other advisors for Client that the other advisors are properly licensed or registered as an investment advisor. This practice represents a conflict of interest as HIA may select Sub-Advisors who charge a lower fee for their services than other Sub-Advisors. This conflict is mitigated by disclosures, procedures, and by the fact that HIA has a fiduciary duty to place the best interest of the Client first and will adhere to their code of ethics. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description The affiliated persons (affiliated persons include employees and/or independent contractors) of HIA have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of HIA affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of HIA. The Code reflects HIA and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. HIA’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other affiliated person, officer or director of HIA 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. - 15 -  HIA’s Code is based on the guiding principle that the interests of the Client are our top priority. HIA’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients’ purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. HIA 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 HIA and its affiliated persons do not recommend to Clients securities in which we have a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest HIA and its affiliated persons may buy or sell securities that are also held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide HIA with copies of their brokerage statements. The Chief Compliance Officer of HIA is Adam Drake. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest HIA does not have a material financial interest in any securities being recommended . However, affiliated persons 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, affiliated persons are required to disclose all reportable securities transactions as well as provide HIA with copies of their brokerage statements. The Chief Compliance Officer of HIA is Adam Drake. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions HIA will recommend the use of a particular broker-dealer based on their duty to seek best execution for the client, meaning they have an obligation to obtain the most favorable terms for a client under the circumstances. The determination of what may constitute best - 16 -  execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is affected, the ability to 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. HIA will select appropriate brokers based on a number of factors including but not limited to their relatively low transaction fees and reporting ability. HIA relies on its broker to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by HIA. HIA does not receive any portion of the trading fees. HIA will recommend the use of Charles Schwab & Co., Inc. • Research and Other Soft Dollar Benefits The Securities and Exchange Commission defines soft dollar practices as arrangement under which products or services other than execution services are obtained by HIA from or through a broker-dealer in exchange for directing Client transactions to the broker-dealer. Although HIA has no formal soft dollar arrangements, HIA may receive products, research and/or other services from custodians or broker-dealers connected to client transactions or “soft dollar benefits”. As permitted by Section 28(e) of the Securities Exchange Act of 1934, HIA receives economic benefits as a result of commissions generated from securities transactions by the custodian or broker-dealer from the accounts of HIA. HIA cannot ensure that a particular client will benefit from soft dollars or the client’s transactions paid for the soft dollar benefits. HIA does not seek to proportionately allocate benefits to client accounts to any soft dollar benefits generated by the accounts. A conflict of interest exists when HIA receives soft dollars which could result in higher commissions charged to Clients. This conflict is mitigated by the fact that HIA has a fiduciary responsibility to act in the best interest of its Clients and the services received are beneficial to all Clients. • Brokerage for Client Referrals HIA does not receive client referrals from any custodian or third party in exchange for using that broker-dealer or third party. • Directed Brokerage Clients who direct brokerage outside our recommendation may be unable to achieve the most favorable execution of client transactions as client directed brokerage may cost clients more money. For example, in a directed brokerage account, you may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or you may receive less favorable prices. Aggregating Securities Transactions for Client Accounts HIA 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 HIA. All Clients participating in the aggregated order shall receive an - 17 -  average share price with all other transaction costs shared on a pro -rated basis. If aggregation if not allowed or infeasible and individual transactions occur (e.g., withdrawal or liquidation requests, odd-lot trades, etc.) an account may potentially be assessed higher costs or less favorable prices than those where aggregation has occurred. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Account reviews are performed quarterly by the Chief Compliance Officer of HIA, Adam Drake. 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 generated are updated as requested by the Client and pursuant to a new or amended agreement, HIA suggests updating at least annually. 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 written account statements no less than quarterly for managed accounts. Account statements are issued by HIA’s custodian. Client receives confirmations of each transaction in account from custodian and an additional statement during any month in which a transaction occurs. Performance reports will be provided by HIA at least quarterly to Clients with assets under management. Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest HIA presently has an arrangement with Calton & Associates, Inc., an SEC Registered Investment Advisor (“RIA”) located in Tampa, Florida, in which Calton’s referring party refer clients to HIA. HIA verifies that the referring RIA firm and their Investment Advisor Representative’s (“IAR”) are properly registered by reviewing IARD/CRD data. In this referral arrangement, the client’s Advisory Fee is as follows: The fee schedule is lower than the one outlined in Item 5 – Fees because, in part, HIA doesn’t not provide financial planning services to these clients. HIA and the referring RIA firm share the fee, and no additional fees are paid by the client. Such referral arrangements can create a conflict of interest in that both HIA and RIA have an interest in obtaining and securing the investment management relationship. Advisory Firm Payments for Client Referrals HIA may enter into agreements with individuals and organizations, which may be affiliated or unaffiliated with HIA, that refer Clients to HIA in exchange for compensation. All such agreements will be in writing and comply with the requirements of Federal or State regulation. If a Client is introduced to HIA by a referring party, HIA may pay that referring - 18 -  party a fee. While the specific terms of each agreement may differ, generally, the compensation will be based upon HIA’s engagement of new Clients and is calculated using a varying percentage of the fees paid to HIA by such Clients. Any such fee shall be paid solely from HIA’s investment management fee, and shall not result in any additional charge to the Client. Each prospective Client who is referred to HIA under such an arrangement will receive a copy of this brochure and a separate written disclosure document disclosing the nature of the relationship between the referring party and HIA and the amount of compensation that will be paid by HIA to the referring party. The referring party is required to obtain the Client’s signature acknowledging receipt of HIA’s disclosure brochure and the referring party’s written disclosure statement. 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 carefully compare the account statements received directly from their custodians to any documentation or reports prepared by HIA. HIA is deemed to have limited custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of HIA. Item 16: Investment Discretion Discretionary Authority for Trading If applicable, Client will authorize HIA discretionary authority, via the advisory agreement, to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. If applicable, Client will authorize HIA discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. If however, consent for discretion is not given, HIA will obtain prior Client approval before executing each transaction. HIA allows Client’s to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. Such restrictions could include only allowing purchases of socially conscious investments. These restrictions must be provided to HIA in writing. The Client approves the custodian to be used and the commission rates paid to the custodian. HIA does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17: Voting Client Securities Proxy Votes HIA 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. When assistance on voting proxies is requested, HIA will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. If the Client requires - 19 -  assistance or has questions, they can reach out to the investment advisor representatives of the firm at the contact information on the cover page of this document. Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided to Clients because HIA does not serve as a custodian for Client funds or securities and HIA does not require prepayment of fees of more than $500 per Client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients HIA has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. Bankruptcy Petitions during the Past Ten Years HIA has not had any bankruptcy petitions in the last ten years. - 20 -  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 Adam Drake, CFA Main Office Address: 466 Town Plaza Ave, Suite 330 Ponte Vedra, FL 32081 WI Address: 175 Patrick Blvd., Suite 120 Brookfield, WI 53045 Tel: 414-755-2309 Toll Free Tel: 877-755-2309 Fax: 414-755-2313 Email: adrake@highlandinvestmentadvisors.com Website: www.highlandinvestmentadvisors.com February 16, 2026 This brochure supplement provides information about Adam Drake and supplements the Highland Investment Advisors, LLC brochure. You should have received a copy of that brochure. Please contact Adam Drake if you did not receive the brochure or if you have any questions about the contents of this supplement. A D D I T I O N A L I N F O R M A T I O N A B O U T A D A M D R A K E ( C R D # 3 2 3 4 1 1 5 ) I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V . - 21 -  Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Principal Executive Officer – Adam Drake, CFA • Year of birth: 1976 Item 2 - Educational Background and Business Experience Educational Background: • University of Wisconsin - Milwaukee; Bachelor of Business Administration in Finance; 2000 Professional Certifications Adam Drake has earned certifications and credentials that are required to be explained in further detail. Chartered Financial Analyst (CFA): Chartered Financial Analysts designation is awarded by the CFA Institute. CFA certification requirements: • Hold a bachelor’s degree from an accredited institution or have equivalent educational or work experience. • Successful completion of all three exam levels of the CFA Program. • Have 48 months of acceptable professional work experience in the investment decision-making process. • Fulfill society requirements, which vary by society. Unless you are upgrading from affiliate membership, all societies require two sponsor statements as part of each application; these are submitted online by your sponsors. • Agree to adhere to and sign the Member's Agreement, a Professional Conduct Statement, and any additional documentation requested by CFA Institute. Business Experience: • Highland Investment Advisors, LLC.; Managing Member/Investment Advisor Representative; 01/2009-Present • Vogel Consulting; Investment Analyst; 08/2008-04/2010 • McSherry & Associates; Portfolio Manager; 07/2005-08/2008 • Capital Financial Services, Inc.; Registered Representative; 07/2005-08/2008 • Robert W Baird & Co; Research Analyst; 07/2003-07/2005 Item 3 - Disciplinary Information 1. Mr. Drake has never been involved in a criminal or civil action in a domestic, foreign or military court of competent jurisdiction for which he: a. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony; (b) misdemeanor that involved investments or an investment-related business, fraud, false statement or omissions, wrongful taking of property, bribery, perjury, counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses; b. Is the named subject of a pending criminal proceeding that involves an investment-related business, fraud, false statements or omissions, wrongful - 22 -  taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses; c. Was found to have been involved in a violation of an investment-related statute or regulation; or d. Was the subject of any order, judgement or decree permanently or temporarily enjoining, or otherwise limiting, him from engaging in any investment related activity, or from violating any investment-related statute, rule, or order. 2. Mr. Drake never had an administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which he: a. Was found to have caused an investment-related business to lose its authorization to do business; or the subject of an order by the agency or authority; b. Was found to have been involved in a violation of an investment-related statute or regulation or was the subject of an order by the agency or authority a. (a)denying, suspending or revoking the authorization of the supervised person to act in an investment-related business; (b) barring or suspending his association with an investment-related business; (c) otherwise significantly limiting his investment-related activities; or (d) imposing a civil money penalty of more than $2,500 on him. 3. Mr. Drake has never been the subject of a self-regulatory organization (SRO) proceeding in which he: a. Was found to have caused an investment-related business to lose its authorization to do business; or b. Was found to have been involved in a violation of the SRO’s rules and was: (a) barred or suspended from membership or from association with other members, or was expelled from membership; (b) otherwise significantly limited from investment-related activities; or (c) fined more than $2,500. 4. Mr. Drake has not been involved in any other hearing or formal adjudication in which a professional attainment, designation, or license of the supervised person was revoked or suspended because of a violation of rules relating to professional conduct. Item 4 - Other Business Activities Mr. Drake does not engage in any outside business activities. Item 5 - Additional Compensation Mr. Drake does not receive any performance-based fees and does not receive any additional compensation for performing advisory services other than what is disclosed in Item 5 of Part 2A. Item 6 - Supervision Mr. Drake is the Chief Compliance Officer of HIA and as such he is solely responsible for all supervision and formulation and monitoring of investment advice offered to Clients. He will adhere to the policies and procedures as described in the firm’s Compliance Manua l. He can be reached at adrake@highlandinvestmnetadvisors.com or 414-755-2309. - 23 -