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Item 1 – Cover Page
Hiley Hunt Wealth Management, Inc.
9850 Nicholas Street, Suite 315
Omaha, NE 68114
(402)504-9347
www.hileyhunt.com
Date of Disclosure Brochure: January 2026
____________________________________________________________________________________
This disclosure brochure provides information about the qualifications and business practices of Hiley Hunt
Wealth Management, Inc. (also referred to as we, us and HHWM throughout this disclosure brochure). If
you have any questions about the contents of this disclosure brochure, please contact Jason D. Hiley at
(402) 504-9347 or jason@hileyhunt.com. The information in this disclosure brochure has not been
approved or verified by the United States Securities and Exchange Commission or by any state securities
authority.
Additional information about HHWM is also available on the Internet at www.adviserinfo.sec.gov. You can
view our firm’s information on this website by searching for Hiley Hunt Wealth Management, Inc. or our
firm’s CRD number 164942.
*Registration as an investment adviser does not imply a certain level of skill or training.
**Although HHWM is referred to as we or us throughout this brochure for your convenience, please
understand that any engagement described under this brochure will be made with the legal entity of Hiley
Hunt Wealth Management, Inc.
Hiley Hunt Wealth Management, Inc.
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Item 2 – Material Changes
Since our last annual update was filed in January 2025, there have been no material changes made to
this disclosure brochure.
We will ensure that you receive a summary of any material changes to this and subsequent disclosure
brochures within 120 days after our firm’s fiscal year ends. The firm’s fiscal year ends on December 31,
so you will receive the summary of material changes no later than April 30 each year. At that time we will
also offer or provide a copy of the most current disclosure brochure. We may also provide other ongoing
disclosure information about material changes, as necessary.
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Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................. 1
Item 2 – Material Changes .................................................................................................................................... 2
Item 3 – Table of Contents .................................................................................................................................... 3
Item 4 – Advisory Business ................................................................................................................................... 4
Introduction ....................................................................................................................................................... 4
Description of Advisory Services ...................................................................................................................... 4
Limits Advice to Certain Types of Investments ................................................................................................. 6
Tailor Advisory Services to Individual Needs of Clients .................................................................................... 7
Client Assets Managed by HHWM .................................................................................................................... 7
Item 5 – Fees and Compensation ......................................................................................................................... 8
Asset Management Services ............................................................................................................................ 8
Financial Planning & Consulting Services ........................................................................................................ 9
Newsletters ..................................................................................................................................................... 12
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 12
Item 7 – Types of Clients .................................................................................................................................... 12
Minimum Investment Amounts Required ........................................................................................................ 12
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .............................................................. 12
Methods of Analysis ........................................................................................................................................ 12
Investment Strategies ..................................................................................................................................... 14
Primarily Recommend One Type of Security .................................................................................................. 15
Risk of Loss .................................................................................................................................................... 15
Item 9 – Disciplinary Information ......................................................................................................................... 16
Item 10 – Other Financial Industry Activities and Affiliations .............................................................................. 17
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ........................................ 17
Code of Ethics Summary ................................................................................................................................ 17
Affiliate and Employee Personal Securities Transactions Disclosure ............................................................. 17
Item 12 – Brokerage Practices ............................................................................................................................ 18
Brokerage Recommendations ........................................................................................................................ 19
Directed Brokerage ......................................................................................................................................... 20
Soft Dollar Benefits ......................................................................................................................................... 20
Handling Trade Errors ..................................................................................................................................... 20
Block Trading Policy ....................................................................................................................................... 20
Agency Cross Transactions ............................................................................................................................ 21
Item 13 – Review of Accounts ............................................................................................................................. 21
Account Reviews and Reviewers .................................................................................................................... 21
Statements and Reports ................................................................................................................................. 21
Item 14 – Client Referrals and Other Compensation .......................................................................................... 22
Item 15 – Custody ............................................................................................................................................... 22
Item 16 – Investment Discretion .......................................................................................................................... 23
Item 17 – Voting Client Securities ....................................................................................................................... 24
Item 18 – Financial Information ........................................................................................................................... 24
Business Continuity Plan .................................................................................................................................... 24
Customer Privacy Policy Notice .......................................................................................................................... 25
Part 2B of Form ADV: Brochure Supplement– Jason D. Hiley ........................................................................... 26
Part 2B of Form ADV: Brochure Supplement– Andrew D. Hunt ......................................................................... 29
Part 2B of Form ADV: Brochure Supplement– Bryce Steven Deane Koch ........................................................ 32
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Item 4 – Advisory Business
HHWM is an S-corporation formed under the laws of the State of Nebraska and has applied to become
registered with the U.S. Securities and Exchange Commission.
•
Jason D. Hiley is the Chief Executive Officer (CEO), President and 51.00% owner of HHWM.
Andrew D. Hunt is the Vice President and 49.00% owner of HHWM.
• HHWM was initially approved as an investment adviser on August 15, 2012.
Introduction
The investment advisory services of HHWM are provided to you through an appropriately licensed
individual who is an investment adviser representative of HHWM (referred to as your investment adviser
representative throughout this brochure). HHWM is a “fee-only” investment adviser. “Fee-only” means we
are paid exclusively by our clients and the amounts of all such compensation are fully disclosed to clients
in writing. We do not sell products and we do not receive commissions or other compensation from any
source. This fee-only arrangement enables our firm to act solely in our clients’ best interests.
Description of Advisory Services
The following are descriptions of the primary advisory services of HHWM. Please understand that a
written agreement, which details the exact terms of the service, must be signed by you and HHWM before
we can provide you the services described below.
Asset Management Services – HHWM offers asset management services, which involves HHWM
providing you with continuous and ongoing supervision over your specified accounts.
All accounts that HHWM will manage on your behalf will be specified in the Asset Management
Agreement that is required to be executed at the initiation of any asset management services (collectively
referred to as the “Account”). In most instances you will appoint our firm as your investment adviser of
record on specified accounts. The Account consists only of separate account(s) held by qualified
custodian(s) under your name. The qualified custodians maintain physical custody of all funds and
securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash,
exercise or delegate proxy voting and receive transaction confirmations) of the Account.
The Account is managed by us based on your financial situation, investment objectives and risk
tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting or
holding securities, cash or other investments of the Account.
We will need to obtain certain information from you to determine your financial situation and investment
objectives. You will be responsible for notifying us of any updates regarding your financial situation, risk
tolerance or investment objective and whether you wish to impose or modify existing investment
restrictions; however we will contact you at least annually to discuss any changes or updates regarding
your financial situation, risk tolerance or investment objectives. We are always reasonably available to
consult with you relative to the status of your Account. You have the ability to impose reasonable
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restrictions on the management of your accounts, including the ability to instruct us not to purchase
certain securities.
It is important that you understand that we manage investments for other clients and may give them
advice or take actions for them or for our personal accounts that is different from the advice we provide to
you or actions taken for you. We are not obligated to buy, sell or recommend to you any security or other
investment that we may buy, sell or recommend for any other clients or for our own accounts.
Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We
strive to allocate investment opportunities believed to be appropriate for your account(s) and other
accounts advised by our firm among such accounts equitably and consistent with the best interests of all
accounts involved. However, there can be no assurance that a particular investment opportunity that
comes to our attention will be allocated in any particular manner. If we obtain material, non-public
information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no
obligation to disclose the information to any client or use it for any client’s benefit.
Financial Planning & Consulting Services - HHWM offers financial planning services, which involve
preparing a written financial plan covering specific or multiple topics. We provide full written financial
plans, which typically address the following topics: Investment Planning, Retirement Planning, Insurance
Planning, Tax Planning, Portfolios Review, and Asset Allocation. When providing financial planning and
consulting services, our role is to find ways to help you understand your overall financial situation and
help you set financial objectives. Written financial plans prepared by us under this Agreement do not
include specific recommendations of individual securities.
Common financial planning topics covered in a plan include:
Investment Planning – HHWM prepares will conduct a detailed review of the client’s overall investment
objective, return requirements, risk tolerance, time horizon, liquidity needs, tax preference, and unique
circumstances. Investment planning can take anywhere between three to forty hours depending upon the
client’s profile and circumstances.
Retirement Planning – HHWM determines retirement income goals and gathers information about
potential sources of retirement. HHWM creates a unified and comprehensive retirement plan covering
assets, income, taxation, inheritance and risk management. A long-term asset management plan is
structured considering economic environment and inflationary conditions, tax minimization strategy,
uncertainty and market volatility. Retirement planning services include research, financial modeling and
mathematical simulation to identify adequacy of client’s investment to attain retirement readiness, and to
clarify strategic choices and actions. Retirement planning can take anywhere between three to fifty hours
depending upon the client’s profile and circumstances.
Insurance Planning – Upon request HHWM will perform a review of clients existing insurance policies
and make recommendations for suggested changes. Insurance reviews can take anywhere between
three and twenty hours depending upon the client’s profile and circumstances.
Tax Planning – HHWM works with third party tax / accounting advisor(s) to align financial goals with tax
efficiency planning. Tax planning would encompass many different aspects e.g. selection of investment
options and types of retirement plans, timing of income and capital growth as well as tax lot selection for
investment transactions within client’s portfolio. Tax planning services would include recommendations on
tax reduction strategies based on income, expenses, individual needs and goals. Clients can also choose
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to use their existing tax / accounting advisor(s). The fee arrangement with an outside professional is
described in the section ‘Other Fee Terms for Financial Planning, Institutional Advisory & Consulting
Services.’ Tax planning can take anywhere between three to forty hours depending upon the client’s
profile and circumstances.
Portfolio Review and Asset Allocation – HHWM researches clients’ existing portfolios and underlying
investments to determine the asset class mix, return profile and risk characteristics. HHWM also
determines broad asset allocation objectives based. An Efficient Frontier is constructed to develop an
optimized portfolio based on the constraints indicated by the client, and underlying investments (e.g.,
stocks, bonds, ETFs, mutual funds) are selected using quantitative screens and qualitative review.
HHWM also analyzes return, risk and modern portfolio statistics and runs mathematical simulations,
wherever necessary, to identify the adequacy of the portfolio against the client’s investment objectives
and risk tolerance. Portfolio Review and asset allocation can take anywhere between three to sixty hours
depending upon the client’s profile and circumstances.
We also offer consultations in order to discuss financial planning issues when you do not need a written
financial plan. We offer a one-time consultation, which covers mutually agreed upon areas of concern
related to investments or financial planning. We also offer “as-needed” consultations, which are limited to
consultations in response to a particular investment or financial planning issue raised or request made by
you. Under an “as-needed” consultation, it will be incumbent upon you to identify those particular issues
for which you are seeking our advice or consultation on.
Topics covered in “as-needed” consultations may include any of the topics typically covered in a
comprehensive plan such as: Investment Planning, Retirement Planning, Insurance Planning, Tax
Planning, Portfolios Review, and Asset Allocation.
Our financial planning and consulting services do not involve implementing any transaction on your behalf
or the active and ongoing monitoring or management of your investments or accounts. You have the sole
responsibility for determining whether to implement our financial planning and consulting
recommendations. To the extent that you would like to implement any of our investment
recommendations through HHWM or retain us to actively monitor and manage your investments, you
must execute a separate written agreement with HHWM for our asset management services.
Newsletters
HHWM occasionally prepares general, educational and informational newsletters and electronic blog
posts. Newsletters and blog posts are always offered on an impersonal basis and do not focus on the
needs of a specific individual.
Limits Advice to Certain Types of Investments
HHWM provides investment advice on the following types of investments:
• Mutual Funds
• Exchange Traded Funds (ETFs)
• Exchange-listed Securities
• Securities Traded Over-the-Counter
• Warrants
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• Corporate Debt Securities
• Commercial Paper
• Certificates of Deposit
• Municipal Securities
• Variable Annuities
• Variable Life Insurance
• US Government Securities
• Options Contracts on Securities
• Options Contracts on Commodities
•
•
Interests in Partnerships Investing in Real Estate
Interests in Partnerships Investing in Oil and Gas Interests
Although HHWM generally provide advice only on the products previously listed, we recommend all types
of securities, and the types of securities will differ based on each client’s individual circumstances.
It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings
modestly as deemed appropriate based on your risk tolerance and our expectations of market behavior.
We may modify our investment strategy to accommodate special situations such as low basis stock, stock
options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations.
(Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more
information.)
Tailor Advisory Services to Individual Needs of Clients
HHWM’s advisory services are always provided based on your individual needs. This means, for
example, that when we provide asset management services, you are given the ability to impose
restrictions on the accounts we manage for you, including specific investment selections and sectors. We
work with you on a one-on-one basis through interviews and questionnaires to determine your investment
objectives and suitability information. Our financial planning and consulting services are always provided
based on your individual needs. When providing financial planning and consulting services, we work with
you on a one-on-one basis through interviews and questionnaires to determine your investment
objectives and suitability information.
We will not enter into an investment adviser relationship with a prospective client whose investment
objectives may be considered incompatible with our investment philosophy or strategies or where the
prospective client seeks to impose unduly restrictive investment guidelines.
Client Assets Managed by HHWM
As of December 31, 2025, HHWM has $289,551,810 in discretionary assets under management. HHWM
has $0 in non-discretionary assets under management.
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Item 5 – Fees and Compensation
In addition to the information provided in Item 4 – Advisory Business, this section provides additional
details regarding our firm’s services along with descriptions of each service’s fees and compensation
arrangements. It should be noted that lower fees for comparable service may be available from other
sources. The exact fees and other terms will be outlined in the agreement between you and HHWM.
Asset Management Services
Fees charged for our asset management services are charged based on a percentage of assets under
management, billed in advance (at the start of the billing period) on a quarterly calendar basis and
calculated based on the fair market value of your account as of the last business day of the previous
billing period. Fees are prorated (based on the number of days service is provided during the initial billing
period) for your account opened at any time other than the beginning of the billing period. If asset
management services are commenced in the middle of the billing period, then the prorated fee for that
billing period is based on the value of the Account at the end of the initial partial quarter and billed in
arrears at the same time that the first full quarter’s fee is billed in advance.
The asset management services continue in effect until terminated by either party (i.e., HHWM or you) by
providing written notice of termination to the other party. Any prepaid, unearned fees will be promptly
refunded by HHWM to you. Fee refunds will be determined on a pro rata basis using the number of days
services are actually provided during the final period. In the event that there is a remaining balance of
any fees paid in advance after the deduction of fees from the final invoice, those remaining proceeds will
be refunded to the Client.
Fees charged for our asset management services are negotiable based on the type of client, the
complexity of the client's situation, the composition of the client's account (i.e., equities versus mutual
funds), the potential for additional account deposits, the personal or professional relationship of the client
with the investment adviser representative, and the total amount of assets under management for the
client.
For our asset management services, client will be charged the following annual fee based upon the
amount of assets under management:
Amount of Assets Under Management Annual Fees
On Amounts from $0 – $2,000,000 1.00%
On the amounts from $2,000,001 – $5,000,000 0.90%
On the amounts from $5,000,001 – $10,000,000 0.80%
On amounts above $10,000,000 0.70%
For example, a client having $6,000,000 in assets under management would be charged 1% on the first
$2,000,000, .90% on the amounts between $2,000,001 and $5,000,000 and .80% on the amounts of
assets under management between $5,000,000 and $6,000,000.
HHWM believes that its annual fee is reasonable in relation to: (1) services provided and (2) the fees
charged by other investment advisers offering similar services/programs. However, our annual
investment advisory fee may be higher than that charged by other investment advisers offering similar
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services/programs. In addition to our compensation, you may also incur charges imposed at the mutual
fund level (e.g., advisory fees and other fund expenses).
You can choose how to pay your investment advisory fees. The investment advisory fees can be
deducted from your account and paid directly to our firm by the qualified custodian(s) of your account or
you can pay our firm upon receipt of a billing notice sent directly to you.
If you choose to have the investment advisory fees deducted from your account, you must authorize the
qualified custodian(s) of your account to deduct fees from your account and pay such fees directly to
HHWM. We will send you a billing statement prior to the time that fee deduction instruction is sent to the
qualified custodian(s) of your account. The billing statement will detail the formula used to calculate the
fee, the assets under management and the time period covered.
You should review your account statements received from the qualified custodian(s) and verify that
appropriate investment advisory fees are being deducted. The qualified custodian(s) will not verify the
accuracy of the investment advisory fees deducted.
If you choose to pay the fees after receiving a statement, fees are due upon your receipt of a billing notice
sent directly to you. The billing notice will detail the formula used to calculate the fee, the assets under
management and the time period covered. Fees for the services of our firm will be due immediately after
your receipt of the billing notice.
Brokerage commissions and/or transaction ticket fees charged by the qualified custodian are billed
directly to you by the qualified custodian. HHWM does not receive any portion of such commissions or
fees from you or the qualified custodian. In addition, you may incur certain charges imposed by third
parties other than HHWM in connection with investments made through your account including, but not
limited to, mutual fund sales loads, 12(b)-1 fees and surrender charges, variable annuity fees and
surrender charges, IRA and qualified retirement plan fees, and charges imposed by the qualified
custodian(s) of your account. Management fees charged by HHWM are separate and distinct from the
fees and expenses charged by investment company securities that may be recommended to you. A
description of these fees and expenses are available in each investment company security’s prospectus.
Financial Planning & Consulting Services
Fees charged for our financial planning and consulting services are negotiable based upon the type of
client, the services requested, the complexity of the client's situation, the composition of the client's
account, other advisory services provided and the personal or professional relationship of the client and
the investment adviser representative. The following are the fee arrangements available for financial
planning and consulting services offered by HHWM.
Fees for Financial Planning Services
HHWM provides financial planning services under an hourly fee arrangement. An hourly fee of $300 per
hour is charged by HHWM for financial planning services under this arrangement. Before commencing
financial planning services, HHWM provides an estimate of the approximate hours needed to complete
the requested financial planning services. If HHWM anticipates exceeding the estimated amount of hours
required, HHWM will contact you to receive authorization to provide additional services. The standard
billing dates and events of HHWM are the following: (1) the first business day of each month; (2) the date
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when incurred hourly fees and expenses will cause the retainer balance to be depleted to zero; (3) the
date or thereafter that HHWM substantially provides the agreed upon services; and (4) the date the
engagement is terminated by either you or HHWM. Upon presentment of the invoice to you, HHWM will
deduct the hourly fees due HHWM against your current retainer balance and you are required to pay
immediately HHWM any outstanding balance of hourly fees due.
To the extent HHWM provides you with general investment recommendations as part of the financial
planning services and you implement such investment recommendations through HHWM, We may offer
in our agreement with you to waive or reduce the fees for financial planning services.
The financial planning services terminate upon delivery of the written financial plan or upon either party
providing the other party with written notice of termination.
You may terminate the financial planning services within five (5) business days of entering into an
agreement with HHWM without penalty or fees due. If you terminate the financial planning services after
five (5) business days of entering into an agreement, you will be responsible for immediate payment of
any financial planning services performed by HHWM prior to the receipt by HHWM of your notice. For
financial planning services performed by HHWM under an hourly arrangement, you will pay HHWM for
any hourly fees incurred at the rates described above.
Fees for Consulting Services
HHWM provides consulting services under an hourly fee arrangement. An hourly fee of $300 per hour is
charged by HHWM for consulting services. Before providing consulting service, HHWM will provide an
estimate of the approximate hours needed to complete the consulting services. If HHWM anticipates
exceeding the estimated amount of hours required, HHWM will contact you to receive authorization to
provide additional services. You may be requested to pay in advance a mutually agreed upon retainer
that will be available for HHWM to bill hourly fees against for our consulting services; however, under no
circumstances will HHWM require you to pay fees more than $500 more than six months in advance. The
standard billing dates and events of HHWM are the following: (1) the first business day of each month; (2)
the date when incurred hourly fees will cause the retainer balance to be depleted to zero; (3) the date or
thereafter that HHWM substantially provides the agreed upon services; and (4) the date the engagement
is terminated by either you or HHWM. Upon presentment of the invoice to you, HHWM will deduct the
hourly fees due HHWM against your current retainer balance and you will immediately pay HHWM any
outstanding balance of hourly fees due.
To the extent HHWM provides you with general investment recommendations as part of our consulting
services and you implement such investment recommendations through us, HHWM at our discretion may
offer to waive or reduce the fee for certain consulting services.
The one-time consulting services will terminate upon completion of the consultation or either party
providing the other party with written notice. The “as-needed” consulting services will terminate upon
either you or HHWM providing written notice of termination to the other party.
You may terminate the consulting services within five (5) business days of entering into an agreement
with HHWM without penalty or fees due. If you terminate the consulting services after five (5) business
days of entering into an agreement with HHWM, you will be responsible for immediate payment of any
consulting work performed by HHWM prior to the receipt by HHWM of your notice. For consulting services
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performed by HHWM under an hourly arrangement, you will pay HHWM for any hourly fees incurred at
the rates described above.
Other Fee Terms for Financial Planning & Consulting Services
You may pay the investment advisory fees owed for the financial planning services by submitting
payment directly (for example, by check) or having the fee deducted from an existing investment account.
If you elect to pay by automatic deduction from an existing investment account, you will provide written
authorization to HHWM for such charge.
To the extent HHWM engages an outside professional (i.e., attorney, independent investment adviser or
accountant) while providing financial planning and consulting services to you, HHWM will be responsible
for the payment of the fees for the services of such an outside professional, and you will not be required
to reimburse HHWM for such payments. To the extent that you personally engage such an outside
professional, you will be responsible for the payment of the fees for the services of such an outside
professional, and HHWM will not be required to reimburse Client for such payments. Fees for the services
of an outside professional (i.e., attorney, independent investment adviser or accountant) will be in addition
to and separate from the fees charged by HHWM, and you will be responsible for the payment of the fees
for the services of such an outside professional. In no event will the services of an outside professional be
engaged without your express approval.
All fees paid to HHWM for services are separate and distinct from the commissions, fees and expenses
charged by insurance companies associated with any disability insurance, life insurance and annuities
subsequently acquired by you. If you sell or liquidate certain existing securities positions to acquire any
insurance or annuity, you may also pay a commission and/or deferred sales charges in addition to the
financial planning and consulting fees paid to HHWM and any commissions, fees and expenses charged
by the insurance company for subsequently acquired insurance and/or annuities.
All fees paid to HHWM for advisory services are separate and distinct from the fees and expenses
charged by mutual funds to their shareholders. These fees and expenses are described in each mutual
fund’s prospectus. These fees will generally include a management fee, other fund expenses and a
possible distribution fee. If the fund also imposes sales charges, you may pay an initial or deferred sales
charge.
All fees paid to HHWM for financial planning and consulting services are separate and distinct from the
commissions charged by a broker-dealer or asset management fees charged by an investment adviser to
implement such recommendations.
If you elect to implement the recommendations of HHWM through our other investment advisory
programs, HHWM may waive or reduce a portion of the investment advisory fees for such investment
advisory program(s). Any reduction will be at the discretion of your investment adviser representative and
disclosed to you prior to contracting for additional investment advisory services.
It should be noted that lower fees for comparable services may be available from other sources.
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Newsletters
Newsletters and blog postings are provided to clients and prospective clients free of charge.
Item 6 – Performance-Based Fees and Side-By-Side Management
Performance-based fees are defined as fees based on a share of capital gains on or capital appreciation
of the assets held in a client’s account. Item 6 is not applicable to this Disclosure Brochure because we
do not charge or accept performance-based fees.
Item 7 – Types of Clients
HHWM generally provides investment advice to the following types of clients:
Individuals
•
• High net worth individuals
• Trusts, estates, or charitable organizations
• Corporations or business entities other than those listed above
• Retirement Plans
You are required to execute a written agreement with HHWM specifying the particular advisory services in
order to establish a client arrangement with HHWM.
Minimum Investment Amounts Required
HHWM does not require a minimum investment amount to open a managed account. However we have
found that our on-going management services are most valuable and actionable for clients with $500,000
or more to invest. Individual circumstances may allow for flexibility surrounding this amount and will be
evaluated on a relationship by relationship basis.
The minimum fee generally charged for a financial planning and consulting services engagement
provided on an hourly basis is $3,000.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
HHWM uses the following methods of analysis in formulating investment advice:
Charting - This is a set of techniques used in technical analysis in which charts are used to plot
price movements, volume, settlement prices, open interest, and other indicators, in order to
anticipate future price movements. Users of these techniques, called chartists, believe that past
trends in these indicators can be used to extrapolate future trends.
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Charting is likely the most subjective analysis of all investment methods since it relies on proper
interpretation of chart patterns. The risk of reliance upon chart patterns is that the next day's data
can always negate the conclusions reached from prior days' patterns. Also, reliance upon chart
patterns bears the risk of a certain pattern being negated by a larger, more encompassing pattern
that has not shown itself yet.
Cyclical –This method analyzes the investments sensitive to business cycles and whose
performance is strongly tied to the overall economy. For example, cyclical companies tend to
make products or provide services that are in lower demand during downturns in the economy
and in higher demand during upswings. Examples include the automobile, steel, and housing
industries. The stock price of a cyclical company will often rise just before an economic upturn
begins, and fall just before a downturn begins. Investors in cyclical stocks try to make the largest
gains by buying the stock at the bottom of a business cycle, just before a turnaround begins.
While most economists and investors agree that there are cycles in the economy that need to be
respected, the duration of such cycles is generally unknown. An investment decision to buy at the
bottom of a business cycle may actually turn out to be a trade that occurs before or after the
bottom of the cycle. If done before the bottom, then downside price action can result prior to any
gains. If done after the bottom, then some upside price action may be missed. Similarly, a sell
decision meant to occur at the top of a cycle may result in missed opportunity or unrealized
losses.
Fundamental – This is a method of evaluating a security by attempting to measure its intrinsic
value by examining related economic, financial and other qualitative and quantitative factors.
Fundamental analysts attempt to study everything that can affect the security's value, including
macroeconomic factors (like the overall economy and industry conditions) and individually
specific factors (like the financial condition and management of a company). The end goal of
performing fundamental analysis is to produce a value that an investor can compare with the
security's current price in hopes of figuring out what sort of position to take with that security
(underpriced = buy, overpriced = sell or short). Fundamental analysis is considered to be the
opposite of technical analysis. Fundamental analysis is about using real data to evaluate a
security's value. Although most analysts use fundamental analysis to value stocks, this method of
valuation can be used for just about any type of security.
The risk associated with fundamental analysis is that it is somewhat subjective. While a
quantitative approach is possible, fundamental analysis usually entails a qualitative assessment
of how market forces interact with one another in their impact on the investment in question. It is
possible for those market forces to point in different directions, thus necessitating an
interpretation of which forces will be dominant. This interpretation may be wrong, and could
therefore lead to an unfavorable investment decision.
Technical – This is a method of evaluating securities by analyzing statistics generated by market
activity, such as past prices and volume. Technical analysts do not attempt to measure a
security's intrinsic value, but instead use charts and other tools to identify patterns that can
suggest future activity. Technical analysts believe that the historical performance of stocks and
markets are indications of future performance.
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Technical analysis is even more subjective than fundamental analysis in that it relies on proper
interpretation of a given security's price and trading volume data. A decision might be made
based on a historical move in a certain direction that was accompanied by heavy volume;
however, that heavy volume may only be heavy relative to past volume for the security in
question, but not compared to the future trading volume. Therefore, there is the risk of a trading
decision being made incorrectly since future trading volume is an unknown. Technical analysis is
also done through observation of various market sentiment readings, many of which are
quantitative. Market sentiment gauges the relative degree of bullishness and bearishness in a
given security, and a contrarian investor utilizes such sentiment advantageously. When most
traders are bullish, then there are very few traders left in a position to buy the security in question,
so it becomes advantageous to sell it ahead of the crowd. When most traders are bearish, then
there are very few traders left in a position to sell the security in question, so it becomes
advantageous to buy it ahead of the crowd. The risk in utilization of such sentiment technical
measures is that a very bullish reading can always become more bullish, resulting in lost
opportunity if the money manager chooses to act upon the bullish signal by selling out of a
position. The reverse is also true in that a bearish reading of sentiment can always become more
bearish, which may result in a premature purchase of a security.
There are risks involved in using any analysis method.
To conduct analysis, HHWM gathers information from financial newspapers and magazines, inspection of
corporate activities, research materials prepared by others, corporate rating services, timing services,
annual reports, prospectuses and filings with the SEC, and company press releases.
Investment Strategies
HHWM uses the following investment strategies when managing client assets and/or providing
investment advice:
Long term purchases. Investments held at least a year.
Short term purchases. Investments sold within a year.
Frequent trading. This strategy refers to the practice of selling investments within 30 days of
purchase.
Short sales. A short sale is generally the sale of a stock not owned by the investor. Investors who
sell short believe the price of the stock will fall. If the price drops, the investor can buy the stock at
the lower price and make a profit. If the price of the stock rises and the investor buys it back later
at the higher price, the investor will incur a loss. Short sales require a margin account.
Margin transactions. When an investor buys a stock on margin, the investor pays for part of the
purchase and borrows the rest of the purchase price from a brokerage firm. For example, an
investor may buy $5,000 worth of stock in a margin account by paying for $2,500 and borrowing
$2,500 from a brokerage firm. Clients cannot borrow stock from HHWM.
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Option writing including cover options, uncovered options or spreading strategies. Options are
contracts giving the purchaser the right to buy or sell a security, such as stocks, at a fixed price
within a specific period of time.
Primarily Recommend One Type of Security
We do not primarily recommend one type of security to clients. Instead, we recommend any product that
may be suitable for each client relative to that client’s specific circumstances and needs.
Risk of Loss
Past performance is not indicative of future results. Therefore, you should never assume that future
performance of any specific investment or investment strategy will be profitable. Investing in securities
(including stocks, mutual funds, and bonds, etc.) involves risk of loss. Further, depending on the different
types of investments there may be varying degrees of risk. You should be prepared to bear investment
loss including loss of original principal.
Because of the inherent risk of loss associated with investing, our firm is unable to represent, guarantee,
or even imply that our services and methods of analysis can or will predict future results, successfully
identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There
are certain additional risks associated with investing in securities through our investment management
program, as described below:
• Market Risk – Either the stock market as a whole, or the value of an individual company,
goes down resulting in a decrease in the value of client investments. This is also referred
to as systemic risk.
• Equity (stock) market risk – Common stocks are susceptible to general stock market
fluctuations and to volatile increases and decreases in value as market confidence in and
perceptions of their issuers change. If you held common stock, or common stock
equivalents, of any given issuer, you would generally be exposed to greater risk than if
you held preferred stocks and debt obligations of the issuer.
• Company Risk. When investing in stock positions, there is always a certain level of
company or industry specific risk that is inherent in each investment. This is also referred
to as unsystematic risk and can be reduced through appropriate diversification. There is
the risk that the company will perform poorly or have its value reduced based on factors
specific to the company or its industry. For example, if a company’s employees go on
strike or the company receives unfavorable media attention for its actions, the value of
the company may be reduced.
• Fixed Income Risk. When investing in bonds, there is the risk that the issuer will default
on the bond and be unable to make payments. Further, individuals who depend on set
amounts of periodically paid income face the risk that inflation will erode their spending
power. Fixed-income investors receive set, regular payments that face the same inflation
risk.
• Options Risk. Options on securities may be subject to greater fluctuations in value than
an investment in the underlying securities. Purchasing and writing put and call options
are highly specialized activities and entail greater than ordinary investment risks.
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• ETF and Mutual Fund Risk – When investing in an ETF or mutual fund, you will bear
additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating
expenses, including the potential duplication of management fees. The risk of owning an
ETF or mutual fund generally reflects the risks of owning the underlying securities the
ETF or mutual fund holds. You will also incur brokerage costs when purchasing ETFs.
• Management Risk – Your investment with our firm varies with the success and failure of
our investment strategies, research, analysis and determination of portfolio securities. If
our investment strategies do not produce the expected returns, the value of the
investment will decrease.
•
Margin Risk - When you purchase securities, you may pay for the securities in full or
borrow part of the purchase price from your account custodian or clearing firm. If you
intended to borrow funds in connection with your Account, you will be required to open a
margin account, which will be carried by the clearing firm. The securities purchased in
such an account are the clearing firm’s collateral for its loan to you.
If those securities in a margin account decline in value, the value of the collateral
supporting this loan also declines, and as a result, the brokerage firm is required to take
action in order to maintain the necessary level of equity in your account. The brokerage
firm may issue a margin call and/or sell other assets in your account.
It is important that you fully understand the risks involved in trading securities on margin,
which are applicable to any margin account that you may maintain, including any margin
account that may be established as part of the Asset Management Agreement
established between you and HHWM and held by the account custodian or clearing firm.
These risks include the following:
• You can lose more funds than you deposit in your margin account.
• The account custodian or clearing firm can force the sale of securities or other assets in
your account.
• The account custodian or clearing firm can sell your securities or other assets without
contacting you.
• You are not entitled to choose which securities or other assets in your margin account
may be liquidated or sold to meet a margin call.
• The account custodian or clearing firm may move securities held in your cash account to
your margin account and pledge the transferred securities.
• The account custodian or clearing firm can increase its “house” maintenance margin
requirements at any time and they are not required to provide you advance written notice.
• You are not entitled to an extension of time on a margin call.
Item 9 – Disciplinary Information
Item 9 is not applicable to this Disclosure Brochure because there are no legal or disciplinary events,
which include criminal actions, civil actions, regulatory proceeding, and/or self-regulatory organization
proceedings, that are material to a client’s or prospective client’s evaluation of our business or integrity.
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Item 10 – Other Financial Industry Activities and Affiliations
HHWM is not and does not have a related person that is a broker/dealer, municipal securities dealer,
government securities dealer or broker, an investment company or other pooled investment vehicle
(including a mutual fund, closed-end investment company, unit investment trust, private investment
company or "hedge fund," and offshore fund), another investment adviser or financial planner, a futures
commission merchant, commodity pool operator, or commodity trading advisor, a banking or thrift
institution, an accountant or accounting firm, a lawyer or law firm, an insurance company or agency, a
pension consultant, a real estate broker or dealer, and a sponsor or syndicator of limited partnerships.
We are an independent registered investment adviser registered with the United States Securities and
Exchange Commission and approved to conduct business in the state jurisdictions where required by
regulation. We are not engaged in any other business activities and offer no other services except those
described in this Disclosure Brochure. However, while We do not sell products or services other than
investment advice, our representatives may sell other products or provide services outside of their role as
investment adviser representatives with us.
Accounting Services
Bryce Koch, an associated person of HHWM, is a licensed CPA. Clients needing assistance with tax
preparation and/or account services may be referred to him but are not obligated to use his services.
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading
Code of Ethics Summary
An investment adviser is considered a fiduciary and has a fiduciary duty to all clients. HHWM has
established a Code of Ethics to comply with the requirements of the securities laws and regulations that
reflects its fiduciary obligations and those of its supervised persons. The Code of Ethics also requires
compliance with federal securities laws. HHWM’s Code of Ethics covers all individuals that are classified
as “supervised persons.” All employees, officers, directors and investment adviser representatives are
classified as supervised persons. HHWM requires its supervised persons to consistently act in your best
interest in all advisory activities. HHWM imposes certain requirements on its affiliates and supervised
persons to ensure that they meet the firm’s fiduciary responsibilities to you. The standard of conduct
required is higher than ordinarily required and encountered in commercial business.
This section is intended to provide a summary description of the Code of Ethics of HHWM. If you wish to
review the Code of Ethics in its entirety, you should send us a written request and upon receipt of your
request, we will promptly provide a copy of the Code of Ethics to you.
Affiliate and Employee Personal Securities Transactions Disclosure
HHWM or associated persons of the firm may buy or sell for their personal accounts, investment products
identical to those recommended to clients. This creates a conflict of interest. It is the express policy of
HHWM that all persons associated in any manner with our firm must place clients’ interests ahead of their
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own when implementing personal investments. HHWM and its associated persons will not buy or sell
securities for their personal account(s) where their decision is derived, in whole or in part, by information
obtained as a result of employment or association with our firm unless the information is also available to
the investing public upon reasonable inquiry.
We are now and will continue to be in compliance with applicable state and federal rules and regulations.
To prevent conflicts of interest, we have developed written supervisory procedures that include personal
investment and trading policies for our representatives, employees and their immediate family members
(collectively, associated persons):
• Associated persons cannot prefer their own interests to that of the client.
• Associated persons cannot purchase or sell any security for their personal accounts prior to
implementing transactions for client accounts.
• Associated persons cannot buy or sell securities for their personal accounts when those
decisions are based on information obtained as a result of their employment, unless that
information is also available to the investing public upon reasonable inquiry.
• Associated persons are prohibited from purchasing or selling securities of companies in which
any client is deemed an “insider.”
• Associated persons are discouraged from conducting frequent personal trading.
• Associated persons are generally prohibited from serving as board members of publicly traded
companies unless an exception has been granted to the Chief Compliance Officer of HHWM.
Any associated person not observing our policies is subject to sanctions up to and including termination.
Item 12 – Brokerage Practices
Clients are under no obligation to act on the financial planning recommendations of HHWM. If the firm
assists in the implementation of any recommendations, we are responsible to ensure that the client
receives the best execution possible. Best execution does not necessarily mean that clients receive the
lowest possible commission costs but that the qualitative execution is best. In other words, all conditions
considered, the transaction execution is in your best interest. When considering best execution, we look
at a number of factors besides prices and rates including, but not limited to:
• Execution capabilities (e.g., market expertise, ease/reliability/timeliness of execution,
responsiveness, integration with our existing systems, ease of monitoring investments)
• Products and services offered (e.g., investment programs, back office services, technology,
regulatory compliance assistance, research and analytic services)
• Financial strength, stability and responsibility
• Reputation and integrity
• Ability to maintain confidentiality
We exercise reasonable due diligence to make certain that best execution is obtained for all clients when
implementing any transaction by considering the back office services, technology and pricing of services
offered.
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Brokerage Recommendations
You are under no obligation to act on the financial planning recommendations of HHWM. If we assist you
in the implementation of any recommendations, we are responsible to ensure that you receive the best
execution possible.
HHWM recommends that you establish brokerage accounts with Charles Schwab through their
Institutional Platform. Charles Schwab (Schwab) is a member of FINRA, SIPC and the NFA. Schwab is
an independent (and unaffiliated) SEC-registered broker-dealer and are recommended by HHWM to
maintain custody of clients' assets and to effect trades for their accounts.
At least annually, we will review alternative custodians in the marketplace for comparison to the currently
used custodian, evaluating criteria such as overall expertise, cost competitiveness, and financial
condition. Quality of execution for custodians will be reviewed through trade journal evaluations.
Schwab offers to independent investment Advisors services which include custody of securities, trade
execution, clearance and settlement of transactions. HHWM is independently owned and operated and
not affiliated with any custodian or broker dealer.
The primary factor in suggesting a broker/dealer or custodian is that the services of the recommended
firm are provided in a cost-effective manner. While quality of execution at the best price is an important
determinant, best execution does not necessarily mean lowest price and it is not the sole consideration.
The trading process of any broker/dealer and money manager suggested by HHWM must be efficient,
seamless, and straight-forward. Overall custodial support services, trade correction services, and
statement preparation are some of the other factors determined when suggesting a broker/dealer.
Schwab provides us with access to their institutional trading and custody services, which are typically not
available to retail investors. These services generally are available to independent investment advisors at
no charge to them so long as the independent investment advisors maintain a minimum amount of assets
with the custodian.
Schwab does not charge separately for custody but is compensated by account holders through
commissions or other transaction-related fees for securities trades that are executed by recommended
money managers through the custodian or that settle into a custodian account.
These benefits include, but are not necessarily limited to: receipt of duplicate client confirmations and
bundled duplicate statements; access to a trading desk; access to block trading which provides the ability
to aggregate securities transactions and allocate the appropriate shares to client accounts; the ability to
have investment advisory fees deducted directly from client accounts; access to an electronic
communications network for client order entry and account information; and access to mutual funds that
generally require significantly higher minimum initial investments or are generally only available to
institutional investors.
Schwab also makes available to us other products and services that benefit our firm but may not benefit
clients' accounts. Some of these other products and services assist us in managing and administering
clients' accounts. These include software and other technology that provide access to client account data
(such as trade confirmation and account statements); provide research, pricing information and other
market data; facilitate payment of the firm’s fees from its clients' accounts; and assist with back-office
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functions; record keeping and client reporting. Many of these services generally may be used to service
all or a substantial number of our accounts, including accounts not maintained at a recommended
custodian. Schwab also provides other services intended to help our firm manage and further develop our
business enterprise. These services may include consulting, publications and conferences on practice
management, information technology, business succession, regulatory compliance and marketing.
Directed Brokerage
Clients are allowed to select the broker-dealer that will be used for their accounts. Clients directing the
use of a particular broker/dealer or other custodian must understand that we may not be able to obtain the
best prices and execution for the transaction. Under a client-directed brokerage arrangement, clients may
receive less favorable prices than would otherwise be the case if the client had not designated a particular
broker/dealer or custodian. Directed brokerage account trades are generally placed by HHWM after
effecting trades for other clients of HHWM. In the event that a client directs HHWM to use a particular
broker or dealer, HHWM may not be authorized to negotiate commissions and may be unable to obtain
volume discounts or best execution. In addition, under these circumstances a disparity in commission
charges may exist between the commissions charged to clients who direct HHWM to use a particular
broker or dealer versus clients who do not direct the use of a particular broker or dealer.
Soft Dollar Benefits
An investment adviser receives soft dollar benefits from a broker-dealer when the investment adviser
receives research or other products and services in exchange for client securities transactions or
maintaining an account balance with the broker-dealer.
HHWM does not have a soft dollar agreement with a broker-dealer or a third-party.
Handling Trade Errors
HHWM has implemented procedures designed to prevent trade errors; however, trade errors in client
accounts cannot always be avoided. Consistent with its fiduciary duty, it is the policy of HHWM to correct
trade errors in a manner that is in the best interest of the client. In cases where the client causes the trade
error, the client is responsible for any loss resulting from the correction. Depending on the specific
circumstances of the trade error, the client may not be able to receive any gains generated as a result of
the error correction. In all situations where the client does not cause the trade error, the client is made
whole and any loss resulting from the trade error is absorbed by HHWM if the error is caused by HHWM.
If the error is caused by the broker-dealer, the broker-dealer is responsible for handling the trade error. If
an investment gain results from the correcting trade, the gain remains in the client’s account unless the
same error involved other client account(s) that should also receive the gains. It is not permissible for all
clients to retain the gain. HHWM may also confer with a client to determine if the client should forego the
gain (e.g., due to tax reasons).
HHWM will never benefit or profit from trade errors.
Block Trading Policy
We may elect to purchase or sell the same securities for several clients at approximately the same time.
This process is referred to as aggregating orders, batch trading or block trading and is used by our firm
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when HHWM believes such action may prove advantageous to clients. If and when we aggregate client
orders, allocating securities among client accounts is done on a fair and equitable basis. Typically, the
process of aggregating client orders is done in order to achieve better execution, to negotiate more
favorable commission rates or to allocate orders among clients on a more equitable basis in order to
avoid differences in prices and transaction fees or other transaction costs that might be obtained when
orders are placed independently.
HHWM uses the pro rata allocation method for transaction allocation.
Under this procedure, pro rata trade allocation means an allocation of the trade at issue among applicable
advisory clients in amounts that are proportional to the participating advisory client’s intended investable
assets. HHWM will calculate the pro rata share of each transaction included in a block order and assigns
the appropriate number of shares of each allocated transaction executed for the client’s account.
If and when we determine to aggregate client orders for the purchase or sale of securities, including
securities in which HHWM or our associated persons may invest, we will do so in accordance with the
parameters set forth in the SEC No-Action Letter, SMC Capital, Inc. Neither we nor our associated
persons receive any additional compensation as a result of block trades.
Agency Cross Transactions
Our associated persons are prohibited from engaging in agency cross transactions, meaning we cannot
act as brokers for both the sale and purchase of a single security between two different clients and cannot
receive compensation in the form of an agency cross commission or principal mark-up for the trades.
Item 13 – Review of Accounts
Account Reviews and Reviewers
Managed accounts are reviewed at least quarterly. While the calendar is the main triggering factor,
reviews can also be conducted at your request. Account reviews will include investment strategy and
objectives review and making a change if strategy and objectives have changed. Reviews are conducted
by the investment advisor representative servicing the client account, with reviews performed in
accordance with your investment goals and objectives.
Our financial planning services terminate upon the presentation of the written plan. Our financial planning
and consulting services do not include monitoring the investments of your account(s), and therefore, there
is no ongoing review of your account(s) under such services.
Statements and Reports
For our asset management services, you are provided with transaction confirmation notices and regular
quarterly account statements directly from the qualified custodian. Additionally, HHWM may provide
position or performance reports to you quarterly and upon request.
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Financial planning clients do not receive any report other than the written plan originally contracted for
and provided by HHWM.
You are encouraged to always compare any reports or statements provided by me, a sub-adviser or third-
party money manager against the account statements delivered from the qualified custodian. When you
have questions about your account statement, you should contact our firm and the qualified custodian
preparing the statement.
Item 14 – Client Referrals and Other Compensation
HHWM has entered into agreements with selected firms (Referring Parties) to refer clients to HHWM. If a
referred client enters into an investment advisory agreement with HHWM, a cash referral fee is paid to the
referring party, which is based upon a percentage of the client advisory fees that are generated. The
referral agreements between any referring party and HHWM will not result in any charges to clients in
addition to the normal level of advisory fees charged.
When a client is referred to us by a referring party, the referring party provides the client with a copy of
our Disclosure Brochure as required by the Investment Advisers Act of 1940. The client also will complete
a Solicitor’s Disclosure Statement document. If the referring party is an unaffiliated registered investment
adviser firm, then the client will also receive a copy of the referring party’s Form ADV Part 2 Disclosure
Brochure. If a referred client enters into an investment advisory agreement with HHWM, a referral fee is
paid to the referring party. The referral relationship will not result in clients being charged any fees over
and above the normal advisory fees charged for the advisory services provided.
The referral agreements between HHWM and referring parties are in compliance with state and federal
securities rules regarding paid solicitor arrangements.
Jason Hiley is responsible for conducting and documenting the initial and annual due diligence review of
each solicitor. In order to ensure that HHWM has fully satisfied its investigation responsibilities, Jason
Hiley will conduct an annual review to examine any material changes the solicitor has made to its
business practices since the last due diligence review. At least annually, Jason Hiley will contact all
solicitors to confirm each solicitor is delivering, at the time of solicitation to all prospects, the solicitor
disclosure statement, Form ADV Part 2A and the Form ADV Part 2B Brochure Supplement(s) for any
supervised person(s) of the adviser who will formulate the investment advice for the client and will have
direct contact with the client, and any supervised person(s) of the adviser who has discretionary authority
over the client’s assets.
Item 15 – Custody
Custody, as it applies to investment advisors, has been defined by regulators as having access or control
over client funds and/or securities. In other words, custody is not limited to physically holding client funds
and securities. If an investment adviser has the ability to access or control client funds or securities, the
investment adviser is deemed to have custody and must ensure proper procedures are implemented.
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HHWM is deemed to have custody of client funds and securities whenever HHWM is given the authority
to have fees deducted directly from client accounts. HHWM is also deemed to have custody of client
funds and securities when HHWM has standing authority (also known as a standing letter of authorization
or “SLOA”) to move money from a client’s account to a third-party account.
It should be noted that authorization to trade in client accounts is not deemed by regulators to be custody.
For accounts in which HHWM is deemed to have custody, we have established procedures to ensure all
client funds and securities are held at a qualified custodian in a separate account for each client under
that client’s name. Clients or an independent representative of the client will direct, in writing, the
establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the
manner in which the funds or securities are maintained. Finally, account statements are delivered directly
from the qualified custodian to each client, or the client’s independent representative, at least quarterly.
Clients should carefully review those statements and are urged to compare the statements against
reports received from HHWM. When clients have questions about their account statements, they should
contact HHWM or the qualified custodian preparing the statement.
When fees are deducted from an account, HHWM is responsible for calculating the fee and delivering
instructions to the custodian. At the same time HHWM instructs the custodian to deduct fees from your
account; HHWM will send you an invoice itemizing the fee. Itemization will include the formula used to
calculate the fee, the amount of assets under management the fee is based on, and the time period
covered by the fee.
Item 16 – Investment Discretion
When providing asset management services, HHWM maintains trading authorization over your Account
and can provide management services on a discretionary basis. When discretionary authority is granted,
we will have the authority to determine the type of securities and the amount of securities that can be
bought or sold for your portfolio without obtaining your consent for each transaction. However, it is the
policy of HHWM to consult with you prior to making significant changes in the account even when
discretionary trading authority is granted.
If you decide to grant trading authorization on a non-discretionary basis, we will be required to contact
you prior to implementing changes in your account. Therefore, you will be contacted and required to
accept or reject our investment recommendations including:
• The security being recommended
• The number of shares or units
• Whether to buy or sell
Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing
of buying or selling an investment and the price at which the investment is bought or sold. If your
accounts are managed on a non-discretionary basis, you need to know that if we are not able to reach
you or you are slow to respond to our request, it can have an adverse impact on the timing of trade
implementations and we may not achieve the optimal trading price.
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You will have the ability to place reasonable restrictions on the types of investments that may be
purchased in your Account. You may also place reasonable limitations on the discretionary power granted
to HHWM so long as the limitations are specifically set forth or included as an attachment to the client
agreement.
Item 17 – Voting Client Securities
HHWM does not vote proxies on behalf of Clients. We have determined that taking on the responsibilities
for voting client securities does not add enough value to the services provided to you to justify the
additional compliance and regulatory costs associated with voting client securities. Therefore, it is your
responsibility to vote all proxies for securities held in Account.
You will receive proxies directly from the qualified custodian or transfer agent; we will not provide you with
the proxies. You are encouraged to read through the information provided with the proxy-voting
documents and make a determination based on the information provided. Although we do not vote client
proxies, if you have a question about a particular proxy feel free to contact me. However, you will have
the ultimate responsibility for making all proxy-voting decisions.
Item 18 – Financial Information
This Item 18 is not applicable to this brochure. HHWM does not require or solicit prepayment of more than
$500 in fees per client, six months or more in advance. Therefore, we are not required to include a
balance sheet for the most recent fiscal year. We are not subject to a financial condition that is
reasonably likely to impair our ability to meet contractual commitments to clients. Finally, HHWM has not
been the subject of a bankruptcy petition at any time.
Business Continuity Plan
HHWM has a business continuity and contingency plan in place designed to respond to significant
business disruptions. These disruptions can be both internal and external. Internal disruptions will impact
our ability to communicate and do business, such as a fire in the office building. External disruptions will
prevent the operation of the securities markets or the operations of a number of firms, such as
earthquakes, wildfires, hurricanes, terrorist attack or other wide-scale, regional disruptions.
Our continuity and contingency plan has been developed to safeguard employees’ lives and firm property,
to allow a method of making financial and operational assessments, to quickly recover and resume
business operations, to protect books and records, and to allow clients to continue transacting business.
The plan includes the following:
• Alternate locations to conduct business;
• Hard and electronic back-ups of records;
• Alternative means of communications with employees, clients, critical business constituents
and regulators; and
• Details on the firms’ employee succession plan
Our business continuity and contingency plan is reviewed and updated on a regular basis to ensure that
the policies in place are sufficient and operational.
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Customer Privacy Policy Notice
In November of 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA). The GLBA requires certain
financial institutions, such as investment adviser firms, to protect the privacy of customer information. In
situations where a financial institution does disclose customer information to non-affiliated third parties,
other than permitted or required by law, customers must be given the opportunity to opt out or prevent
such disclosure. Hiley Hunt Wealth Management does not share or disclose customer information to non-
affiliated third parties except as permitted or required by law.
Hiley Hunt Wealth Management is committed to safeguarding the confidential information of its clients.
Hiley Hunt Wealth Management holds all personal information provided by clients in the strictest
confidence and it is the objective of Hiley Hunt Wealth Management to protect the privacy of all clients.
Except as permitted or required by law, Hiley Hunt Wealth Management does not share confidential
information about clients with non-affiliated parties. In the event that there were to be a change in this
policy, Hiley Hunt Wealth Management will provide clients with written notice and clients will be provided
an opportunity to direct Hiley Hunt Wealth Management as to whether such disclosure is permissible.
To conduct regular business, Hiley Hunt Wealth Management may collect personal information from
sources such as:
•
•
•
Information reported by the client on applications or other forms the client provides to Hiley Hunt
Wealth Management
Information about the client’s transactions implemented by Hiley Hunt Wealth Management or
others
Information developed as part of financial plans, analyses or investment advisory services
To administer, manage, service and provide related services for client accounts, it is necessary for Hiley
Hunt Wealth Management to provide access to customer information within the firm and to non-affiliated
companies, (optional to include examples of outside firms), with whom Hiley Hunt Wealth Management
has entered into agreements. To provide the utmost service, Hiley Hunt Wealth Management may
disclose the information below regarding customers and former customers, as necessary, to companies
to perform certain services on Hiley Hunt Wealth Management’s behalf.
•
•
•
•
Information Hiley Hunt Wealth Management receives from the client on applications (name,
Social Security number, address, assets, etc.)
Information about the client’s transactions with Hiley Hunt Wealth Management or others
(account information, payment history, parties to transactions, etc.)
Information concerning investment advisory account transactions
Information about a client’s financial products and services transaction with Hiley Hunt Wealth
Management
Since Hiley Hunt Wealth Management shares non-public information solely to service client accounts,
Hiley Hunt Wealth Management does not disclose any non-public personal information about Hiley Hunt
Wealth Management’s customers or former customers to anyone, except as permitted by law. However,
Hiley Hunt Wealth Management may also provide customer information outside of the firm as required by
law, such as to government entities, consumer reporting agencies or other third parties in response to
subpoenas. In the event that Hiley Hunt Wealth Management has a change to its customer privacy policy
that would allow it to disclose non-public information not covered under applicable law, Hiley Hunt Wealth
Management will allow its clients the opportunity to opt out of such disclosure.
Hiley Hunt Wealth Management, Inc.
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Part 2B of Form ADV: Brochure Supplement– Jason D. Hiley
Jason D. Hiley
Hiley Hunt Wealth Management, Inc.
9850 Nicholas Street, Suite 315
Omaha, NE 68114
(402)504-9347
www.hileyhunt.com
Date of Disclosure Brochure: January 2026
This brochure supplement provides information about Jason D. Hiley that supplements the Hiley Hunt
Wealth Management brochure. You should have received a copy of that brochure. Please contact Jason
at (402) 504-9347 or jason@hileyhunt.com if you did not receive Hiley Hunt Wealth Management’s
brochure or if you have any questions about the contents of this supplement.
Additional information about Jason is available on the SEC's website at www.adviserinfo.sec.gov.
Hiley Hunt Wealth Management, Inc.
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Item 2 Educational, Background and Business Experience
Full Legal Name: Jason D. Hiley, CRD #4557060 Born: 1975
Educational Background:
Bachelor of Science Business Administration - Accounting and Management Information Systems
University of Iowa, Iowa City, IA
Business Experience:
Hiley Hunt Wealth Management, Inc., CEO and President, 07/2012 to Present;
Karstens Investment Counsel, Inc., Investment Advisor Representative, 01/2006 to 07/2012;
McCarthy Group Advisors, LLC, Investment Advisor Representative, 07/2004 to 12/2005
Item 3 Disciplinary Information
Jason Hiley has not been the subject of:
A. A criminal or civil action in a domestic, foreign or military court of competent jurisdiction in
which the he:
2.
1. was convicted of, or pled 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;
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;
3. was found to have been involved in a violation of an investment-related statute or
regulation; or
4. was the subject of any order, judgment, or decree permanently or temporarily enjoining,
or otherwise limiting, the supervised person from engaging in any investment-related
activity, or from violating any investment-related statute, rule, or order.
B. An administrative proceeding before the SEC, any other federal regulatory agency, any state
regulatory agency, or any foreign financial regulatory authority in which the he:
1. was found to have caused an investment-related business to lose its authorization to do
business; or
2. was found to have been involved in a violation of an investment-related statute or
regulation and was the subject of an order by the agency or authority
(a) denying, suspending, or revoking the authorization of the supervised person to act in
an investment-related business;
(b) barring or suspending the supervised person's association with an investment-related
business;
Hiley Hunt Wealth Management, Inc.
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(c) otherwise significantly limiting the supervised person's investment-related activities;
or
(d) imposing a civil money penalty of more than $2,500 on the supervised person.
C. A self-regulatory organization (SRO) proceeding in which he:
1. was found to have caused an investment-related business to lose its authorization to
do business; or
2. was found to have been involved in a violation of the SRO’s rules and was: (i) barred
or suspended from membership or from association with other members or was expelled
from membership; (ii) otherwise significantly limited from investment-related activities; or
(iii) fined more than $2,500.
D. Any other proceeding in which a professional attainment, designation, or his license was
revoked or suspended because of a violation of rules relating to professional conduct
Item 4 Other Business Activities
Jason has no other business activities.
Item 5 Additional Compensation
Jason does not receive any economic benefit from a non-advisory client for the provision of investment
advisory services.
Item 6 Supervision
Jason D. Hiley is the Chief Compliance Officer of HHWM. He is responsible for developing, overseeing
and enforcing the firm’s compliance programs that have been established to monitor and supervise the
activities and services provided by the firm and its representatives, including Jason D. Hiley. Mr. Hiley can
be contacted at (402)504-9347.
Hiley Hunt Wealth Management, Inc.
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Part 2B of Form ADV: Brochure Supplement– Andrew D. Hunt
Andrew D. Hunt
Hiley Hunt Wealth Management, Inc.
9850 Nicholas Street, Suite 315
Omaha, NE 68114
(402)504-9347
www.hileyhunt.com
Date of Disclosure Brochure: January 2026
This brochure supplement provides information about Andrew D. Hunt that supplements the Hiley Hunt
Wealth Management brochure. You should have received a copy of that brochure. Please contact
Andrew at (402) 504-9347 or andrew@hileyhunt.com if you did not receive Hiley Hunt Wealth
Management’s brochure or if you have any questions about the contents of this supplement.
Additional information about Andrew is available on the SEC's website at www.adviserinfo.sec.gov.
Hiley Hunt Wealth Management, Inc.
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Item 2 Educational, Background and Business Experience
Full Legal Name: Andrew D. Hunt, CRD # 5657526 Born: 1986
Educational Background:
Bachelor of Science Business Administration-Accounting, University of Nebraska - Omaha,
Omaha, NE
Masters of Business Administration, University of Nebraska - Omaha, Omaha, NE
Certificate of Financial Planning, Boston University, Boston, MA
Business Experience:
Hiley Hunt Wealth Management, Inc., Vice President and Owner 01/2017 to Present;
Hiley Hunt Wealth Management, Inc., Investment Advisor Representative 03/2015 to Present;
Gallup Federal Credit Union, Consultant, 11/2013 to 03/2015;
Guide Rock Capital Management, Inc., Investment Adviser Representative/Insurance Agent,
09/2009 to 03/2015;
Guide Rock Capital Management, Inc., Insurance Agent, 09/2009 to 03/2015;
Gallup Federal Credit Union, V.P. of Operations, 01/2007 to 11/2013;
Gallup Federal Credit Union, Investment Adviser Representative, 06/2009 to 09/2009
Item 3 Disciplinary Information
Andrew D. Hunt has not been the subject of:
A. A criminal or civil action in a domestic, foreign or military court of competent jurisdiction in
which the he:
2.
1. was convicted of, or pled 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;
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;
3. was found to have been involved in a violation of an investment-related statute or
regulation; or
4. was the subject of any order, judgment, or decree permanently or temporarily
enjoining, or otherwise limiting, the supervised person from engaging in any
investment-related activity, or from violating any investment-related statute, rule, or
order.
B. An administrative proceeding before the SEC, any other federal regulatory agency, any state
regulatory agency, or any foreign financial regulatory authority in which the he:
1. was found to have caused an investment-related business to lose its authorization to
do business; or
Hiley Hunt Wealth Management, Inc.
Page 30
2. was found to have been involved in a violation of an investment-related statute or
regulation and was the subject of an order by the agency or authority
(a) denying, suspending, or revoking the authorization of the supervised person to
act in an investment-related business;
(b) barring or suspending the supervised person's association with an investment-
related business;
(c) otherwise significantly limiting the supervised person's investment-related
activities; or
(d) imposing a civil money penalty of more than $2,500 on the supervised person.
C. A self-regulatory organization (SRO) proceeding in which he:
1. was found to have caused an investment-related business to lose its authorization to
do business; or
2. was found to have been involved in a violation of the SRO’s rules and was: (i) barred
or suspended from membership or from association with other members or was
expelled from membership; (ii) otherwise significantly limited from investment-related
activities; or (iii) fined more than $2,500.
D. Any other proceeding in which a professional attainment, designation, or his license was
revoked or suspended because of a violation of rules relating to professional conduct
Item 4 Other Business Activities
Andrew is also engaged as a Director of DayCloud Studios, LLC a full service creative agency which
offers traditional and new media advertising services. He spends less than 5 hours per week on this
activity.
Item 5 Additional Compensation
Andrew does not receive any economic benefit from a non-advisory client for the provision of investment
advisory services.
Item 6 Supervision
Jason D. Hiley is the Chief Compliance Officer of HHWM. He is responsible for developing, overseeing
and enforcing the firm’s compliance programs that have been established to monitor and supervise the
activities and services provided by the firm and its representatives, including Andrew D. Hunt. Mr. Hiley
can be contacted at (402)504-9347.
Hiley Hunt Wealth Management, Inc.
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Part 2B of Form ADV: Brochure Supplement– Bryce Steven Deane Koch
Bryce Koch
Hiley Hunt Wealth Management, Inc.
9850 Nicholas Street, Suite 315
Omaha, NE 68114
(402)504-9347
www.hileyhunt.com
Date of Disclosure Brochure: January 2026
This brochure supplement provides information about Bryce Koch that supplements the Hiley Hunt
Wealth Management brochure. You should have received a copy of that brochure. Please contact Bryce
at (402) 504-9347 or bryce@hileyhunt.com if you did not receive Hiley Hunt Wealth Management’s
brochure or if you have any questions about the contents of this supplement.
Additional information about Bryce is available on the SEC's website at www.adviserinfo.sec.gov.
Hiley Hunt Wealth Management, Inc.
Page 32
Item 2 Educational, Background and Business Experience
Full Legal Name: Bryce Steven Deane Koch, CRD # 6792710 Born: 1994
Educational Background:
Bachelor of Science in Accounting, Morningside University, 2017
Business Experience:
Hiley Hunt Wealth Management, Inc., Financial Planner, 01/2024 to Present;
Hiley Hunt Wealth Management, Inc., Senior Associate, 05/2022 to 12/31/2024;
Frankel Zacharia, Senior Tax Accountant (Part Time), 05/2022 to 1/2023;
Frankel Zacharia, Senior Tax Accountant, 09/2020 to 05/2022;
Kiewit Corporation, Tax Accountant, 09/2019 to 09/2020;
Woodmen Life, Tax Accountant, 05/2017 to 09/2019.
Professional Designations
Certified Public Accountant (CPA)
A Certified Public Accountant (CPA) primarily provides financial audit services, including attesting to the
reasonableness of disclosures, freedom from material misstatements and adherence to applicable
generally accepted accounting principles. To become a CPA, a candidate must pass the Uniform Certified
Public Accountant Examination set by the American Institute of Certified Public Accountants and
administered by the National Association of State Boards of Accountancy. Typically, eligibility to sit for the
examination requires a candidate to have a Bachelor’s Degree that includes a minimum number of
qualifying credit hours in accounting and business administration plus an additional one year
study. Candidates are also required to have public accounting work experience, with minimum
requirements varying from state to state. Applicants for CPA status must also complete a special
examination on ethics, including a review of state specific rules for professional practice. All CPAs are
required to take continuing education courses. The requirements vary by state but usually require 120
hours of continuing education every three years with at least 20 hours taken every year. Many states
require CPAs to take an ethics course during every renewal period, with courses ranging from 2-8 hours.
Item 3 Disciplinary Information
Bryce Koch has not been the subject of:
A. A criminal or civil action in a domestic, foreign or military court of competent jurisdiction in
which he:
2.
1. was convicted of, or pled 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;
is the named subject of a pending criminal proceeding that involves an investment-
related business, fraud, false statements or omissions, wrongful taking of property,
Hiley Hunt Wealth Management, Inc.
Page 33
bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these
offenses;
3. was found to have been involved in a violation of an investment-related statute or
regulation; or
4. was the subject of any order, judgment, or decree permanently or temporarily enjoining,
or otherwise limiting, the supervised person from engaging in any investment-related
activity, or from violating any investment-related statute, rule, or order.
B. An administrative proceeding before the SEC, any other federal regulatory agency, any state
regulatory agency, or any foreign financial regulatory authority in which he:
1. was found to have caused an investment-related business to lose its authorization to do
business; or
2. was found to have been involved in a violation of an investment-related statute or
regulation and was the subject of an order by the agency or authority
a) denying, suspending, or revoking the authorization of the supervised person to
act in an investment-related business;
b) barring or suspending the supervised person's association with an investment-
related business;
c) otherwise significantly limiting the supervised person's investment-related
d)
activities; or
imposing a civil money penalty of more than $2,500 on the supervised person.
C. A self-regulatory organization (SRO) proceeding in which he:
1. was found to have caused an investment-related business to lose its authorization to
do business; or
2. was found to have been involved in a violation of the SRO’s rules and was: (i) barred
or suspended from membership or from association with other members or was
expelled from membership; (ii) otherwise significantly limited from investment-related
activities; or (iii) fined more than $2,500.
D. Any other proceeding in which a professional attainment, designation, or his license was
revoked or suspended because of a violation of rules relating to professional conduct
Item 4 Other Business Activities
Certified Public Accountant
Bryce Koch is a Certified Public Accountant (CPA). If Bryce Koch determines that a client is in need of tax
or accounting services, the client may be referred to Bryce Koch’s accounting services. In addition, if
accounting or tax clients of Bryce Koch are in need of financial planning or other advisory services, Bryce
Koch acting in his or her separate capacity as an accountant may refer or recommend investment
services available through HHWM.
Clients are not obligated in any manner to use the services, or an accounting firm recommended or
owned by Bryce Koch.
Hiley Hunt Wealth Management, Inc.
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Item 5 Additional Compensation
Bryce does not receive any economic benefit from a non-advisory client for the provision of investment
advisory services.
Item 6 Supervision
Jason D. Hiley is the Chief Compliance Officer of HHWM. He is responsible for developing, overseeing
and enforcing the firm’s compliance programs that have been established to monitor and supervise the
activities and services provided by the firm and its representatives, including Bryce Koch. Mr. Hiley can be
contacted at (402)504-9347.
Hiley Hunt Wealth Management, Inc.
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