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Disclosure Brochure
Dated September 8th, 2025
Item 1 – Cover Page
This Brochure provides information about the qualifications and business practices of Hill
Investment Group Partners, LLC (“HIG”). If you have any questions about the contents of this
Brochure, please contact us at (314) 448-4023. The information in this Brochure has not been
approved or verified by the United States Securities and Exchange Commission or by any state
securities authority.
HIG is a registered investment adviser. Registration of an Investment Adviser does not imply
any level of skill or training. The oral and written communications provide you with information
to determine to hire or retain HIG as an Advisor.
HIG provides investment advisory services under the Hill Investment Group name and under
Hillfolio, Longview Research Partners, and Hilltop Family Office. Hillfolio, Longview Research
Partners, and Hilltop Family Office are each a DBA (“doing business as”) of HIG.
Locations and Contact Information
Houston Office
2001 Kirby Drive
Suite 750
Houston, TX 77019
HillInvestmentGroup.com
tel 713 533 1200
tel 855 414 5500
Nashville Office
5300 Maryland Way
Suite 303
Brentwood, TN 37027
EmeraldSpectrum.com
tel 615 369 0690
tel 855 414 5500
Saint Louis Office
190 Carondelet Plaza
Suite 1475
Saint Louis, MO 63105
HillInvestmentGroup.com
tel 314 448 4023
tel 855 414 5500
Additional information about HIG is also available via the SEC’s website www.advisorinfo.sec.gov.
You can search this site by a unique identifying number, known as a CRD number. The CRD
number for HIG is 312052. The SEC’s website also provides information about any persons
affiliated with HIG who are registered or are required to be registered as investment adviser
representatives of HIG.
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Item 2 - Material Changes
Since our annual updating amendment on March 30th, 2024, we have made the following material
changes:
• Our St. Louis location moved to The Plaza in Clayton: 190 Carondelet Plaza, Suite 1475, St.
Louis, MO 63105.
• With effect from September 13, 2024, HIG (doing business as Longview Research Partners)
was appointed as investment adviser to the Longview Advantage ETF, a series portfolio of the
RBB Fund Trust, a Delaware Statutory Trust registered as an open-end management
investment company under the Investment Company Act of 1940.
• We offer clients the option of obtaining cash management solutions from unaffiliated third-
party financial institutions through Flourish Financial LLC (“Flourish”). Further information
on this conflict of interest is available in Items 4, 5, and 10 of this Brochure.
• We have updated our standard fee schedule under Item 5 of this Brochure.
We will provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge. You may request our brochure by contacting Nell Schiffer at (314)
448-4023.
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Item 3 - Table of Contents
Item 1 – Cover Page
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Item 2 - Material Changes
2
Item 3 - Table of Contents
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Item 4 – Advisory Business
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Item 5 – Fees and Compensation
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Item 6 – Performance-Based Fees and Side-By-Side Management
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Item 7 – Types of Clients
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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
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Item 9 – Disciplinary Information
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Item 10 – Other Financial Industry Activities and Affiliations
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Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
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Item 12 – Brokerage Practices
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Item 13 – Review of Accounts
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Item 14 – Client Referrals and Other Compensation
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Item 15 – Custody
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Item 16 – Investment Discretion
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Item 17 – Voting Client Securities
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Item 18 – Financial Information
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Item 4 – Advisory Business
In 2021, Hill Investment Group Partners, LLC (“HIG”) acquired the advisory business of Hill
Investment Group, LLC, who has been providing advisory services since 2005. In 2022, Hill
Investment Group Partners, LLC (“HIG”) acquired the advisory business of Emerald Spectrum
Advisory, who has been providing advisory services since 1998. HIG serves five main client
segments: Hillfolio, Hill, Hilltop, Hill Institutional, and Longview Advantage ETF.
Some of the segments are referred to specifically below. Where HIG is used, the information
applies to the collective firm, which includes all segments. As of December 31st, 2025 the
regulatory assets HIG manages total $1,042,455,740.
Hill Investment Group is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership.
Specifically, Hill Investment Group is a wholly-owned indirect subsidiary of Focus LLC.
Focus Financial Partners Inc. is the sole managing member of Focus LLC. Ultimate governance
of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP.
Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with
Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital
LLC (“Stone Point”) are indirect owners of Focus LLC. Because Hill Investment Group is an
indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are
indirect owners of Hill Investment Group.
Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants,
insurance firms, business managers and other firms (the “Focus Partners”), most of which
provide wealth management, benefit consulting and investment consulting services to
individuals, families, employers, and institutions. Some Focus Partners also manage or advise
limited partnerships, private funds, or investment companies as disclosed on their respective
Form ADVs.
HIG is managed by Matt Hall, Nell Schiffer, and Matt Zenz (“HIG Principals”), pursuant to a
management agreement between HIG Management, LLC and HIG. The HIG Principals serve as
officers and leaders of HIG and are responsible for the management, supervision, and oversight of
HIG.
As fiduciaries, we have duties of care and of loyalty to clients and are subject to obligations
imposed on us by the federal and state securities laws. As a result, clients have certain rights
that clients cannot waive or limit by contract. Nothing in HIG’s agreement with clients should
be interpreted as a limitation of HIG’s obligations under the federal and state securities laws or
as a waiver of any unwaivable rights clients possess. While HIG enters into advisory
agreements with clients, it does not enter into a written agreement with investors in the
Longview Advantage ETF, and such investors are not considered advisory clients of HIG unless
they are also an advisory client of HIG. With respect to the Longview Advantage ETF, this
Brochure is qualified in its entirety by the Longview Advantage ETF’s prospectus, statement of
additional information and related disclosure (collectively, “offering documents”).
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Longview Advantage ETF
On September 13, 2024, HIG, through its service line branded as Longview Research Partners
(“Longview”), was appointed as investment adviser to the Longview Advantage ETF, a series
portfolio of the RBB Fund Trust, a Delaware Statutory Trust registered as an open-end
management investment company under the Investment Company Act of 1940 (the
“Investment Company Act”). HIG provides portfolio management services to the Longview
Advantage ETF through an integrated investment approach that combines research, portfolio
design, portfolio management, and trading functions. HIG will primarily invest in equity
securities of a diverse group of U.S. companies across market sectors, market capitalizations,
and industry groups through the Longview Advantage ETF. Services provided by HIG include the
selection of individual stocks to purchase and sell, rebalancing decisions, trading direction,
proxy voting, and corporate action elections. The Longview Advantage ETF is managed by HIG
according to the ETF’s investment guidelines and restrictions and is not tailored to the
individual needs of any particular investor.
Wealth Management Services
HIG provides investment management and financial planning services for clients through
service lines branded as Hillfolio, Hilltop Family Office, and Hill Investment Group. Hillfolio and
Hilltop Family Office are registered as DBA (doing business as) for HIG. HIG charges clients a fee
for services. Details under Item 5 Fees and Compensation.
HIG provides investment management and holistic wealth management services, including
financial planning and advising on tax, estate and insurance needs. HIG determines, with the
client, their investment objectives and investor risk profile. HIG works with clients to create
written investment objectives or a written investment policy statement based on the client’s
goals and risk tolerance.
HIG uses investment and portfolio allocation software to evaluate alternative portfolio designs.
HIG evaluates the client's existing investments against the client's goals. HIG works with new
clients to develop a plan to transition from the client's existing portfolio to the portfolio
recommended by HIG. HIG monitors the client's portfolio holdings and overall asset allocation
strategy at least quarterly and holds regular review meetings with the client regarding the
account.
HIG typically creates a recommended portfolio of no-load mutual funds and ETFs and may use
model portfolios if the models match the client's investment goals. Subject to obtaining
appropriate client consent, HIG also recommends and allocates the Longview Advantage ETF
within such portfolios. HIG allocates the client's assets among various investments, considering
the client’s overall risk profile. HIG’s recommended funds generally follow a rules-based asset
class investment philosophy with low turnover. Although purchasing individual equity securities
is never a part of our recommended investment strategy, client portfolios may include
individual equity securities with significant unrealized capital gains or held for sentimental
purposes. HIG manages portfolios on a discretionary basis.
HIG may also recommend fixed income securities to advisory clients, consisting of fixed
income funds and or managed accounts of individual bonds. HIG requests discretionary
authority from advisory clients to manage equity and fixed income portfolios.
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HIG implements investment advice on behalf of certain clients in held-away accounts that are
maintained at independent third-party custodians. These held-away accounts are often 401(k)
accounts, 529 plans and other assets that are not held at our primary custodian(s). The order
management system that HIG uses for held-away accounts is provided by Pontera Solutions,
Inc. HIG reviews, monitors, and manages these held-away accounts in an integrated way with
client accounts held at our primary custodian(s). Further information about this service is
available in Item 5.
Portfolio Management Specifics for Institutional Intelligent Portfolios
Some clients may use the Institutional Intelligent Portfolios® (IIP) platform, an automated,
online investment management platform for independent investment advisors offered by
Schwab Performance Technologies (an affiliate of Charles Schwab & Co., “Schwab”).
Schwab is a FINRA member broker-dealer. HIG contracts Schwab for the technology
platform, related trading, and account management services for Hillfolio. The platform
includes automated rebalancing and tax-loss harvesting (if the client is eligible and
elects).
IIP client portfolios are held in a brokerage account at Schwab. Schwab’s role with HIG client
care is limited to delivering the Disclosure Brochure and ensuring the platform operates as
described. Clients do not pay brokerage commissions to Schwab as part of the Institutional
Intelligent Portfolios® platform. HIG is independent of and not owned by, affiliated with,
sponsored or supervised by Schwab.
HIG, not Schwab, is the client’s investment advisor and primary point of contact.
HIG charges clients fees for our services under Item 5 Fees and Compensation. Clients do not
pay Schwab brokerage commissions as part of HIG services. Schwab does receive other
revenues, including (i) the profit earned by Charles Schwab Bank, SSB, a Schwab affiliate, on the
allocation to the Schwab Intelligent Portfolios Sweep Program described in the Schwab
Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/or
administrative service fees (or unitary fees) received by Charles Schwab Investment
Management, Inc., a Schwab affiliate, from Schwab ETFs™ Schwab Funds®; (iii) fees received
by Schwab from mutual funds in the Schwab Mutual Fund Marketplace®; and (iv)
remuneration Schwab receives from the market centers where it routes ETF trade orders for
execution.
Hill Institutional, ERISA
HIG provides advisory services to institutions, including participant-directed employee
retirement benefit plans. HIG analyzes the institution’s current investment platform and assists
the institution in recommending investment offerings. HIG recommends investment options to
achieve the institution’s objectives, provides sponsor education, and monitors the performance
of the institution’s investment vehicles. HIG recommends changes in the institution’s
investments as needed. HIG may provide participant-level education as a part of this service.
For ERISA plans custodied at Ascensus or ADP, HIG serves as the ERISA 3(21) fiduciary advisor to
the Plan. HIG consults with the Trustees on all aspects of the Plan, assists in building model
portfolio allocations and choosing investment options for the Plan, and provides advice to
participants. HIG has non-discretionary authority - meaning the client retains and exercises the
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final decision-making authority for implementing or rejecting HIG’s recommendations. Because
of the nature services provided, these plans are not considered a part of regulatory AUM.
For ERISA plans, individual retirement accounts, or institutional accounts custodied at Schwab
or Fidelity, HIG serves as a fiduciary with discretionary authority - meaning HIG has the
authority to make the investment decisions in its sole discretion without the client’s prior
approval. These authorities are reflected in HIG’s Investment Advisory Agreement.
HIG is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”) with respect to investment management services and investment advice provided
to ERISA plan clients, including plan participants. HIG is also a fiduciary under section 4975
of the Internal Revenue Code (the “IRC”) with respect to investment management
services and investment advice provided to individual retirement accounts (“IRAs”), ERISA
plans, and ERISA plan participants. As such, HIG is subject to specific duties and obligations
under ERISA and the IRC, as applicable, that include, among other things, prohibited transaction
rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a
fiduciary gives advice, the fiduciary must either avoid or eliminate certain conflicts of
interest or rely upon a prohibited transaction exemption (a “PTE”).
Credit and Cash Management Solutions
HIG offers clients the option of obtaining certain financial solutions from unaffiliated third-
party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with
UPTIQ, Inc. and its affiliates, “UPTIQ”) and Flourish Financial LLC (“Flourish”). Please see Items 5
and 10 for a discussion of these services and other important information.
Focus Risk Solutions
HIG helps our clients obtain certain insurance solutions by introducing clients to our affiliate,
Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus
Financial Partners, LLC. Please see Items 5 and 10 for a discussion of this service and other
important information.
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Item 5 – Fees and Compensation
Asset Management and Planning Fees
HIG manages investment portfolios for individuals, families, qualified retirement plans, trusts,
and small businesses typically according to a blended fee schedule based on a client’s assets
under management (“AUM”) with HIG. Clients with less than $1 million in AUM are typically
charged a fee of 1.25%. Once a client’s AUM exceeds $1 million, the client will typically be billed in
accordance with the following blended fee schedule:
From
To
%
$ 1,000,000
$
$
$ -
0.95
$ 1,000,000
5,000,000 0.85
10,000,000 0.70
5,000,000
$
10,000,000 $ 50,000,000 0.50
$
0.40
50,000,000 +
$
HIG provides cash management services for 30 bps.
HIG generally requires a minimum annual fee for investment management and financial
planning services. This annual minimum fee ranges from $2,550 to $40,000 depending on
client profile and complexity. HIG can provide estate coordination services, and the minimum
planning fee ranges from $2,550 to $40,000 depending on complexity.
Hillfolio, Hill, and Hilltop clients are billed quarterly in advance. HIG Institutional company
401ks at Ascensus and ADP are billed quarterly in arrears.
Clients provide written limited authorization for HIG to withdraw fees directly from client
accounts, held by an independent custodian. 401k clients custodied at Ascensus and ADP are
invoiced quarterly, in arrears, and employers provide written limited authorization to HIG to
withdraw fees from the accounts or issue an invoice directly.
The specific fee rate applicable to each client is set forth in our investment advisory agreement
with the client. At HIG’s discretion, investment management fees for certain clients differ from
the fee schedule above. In certain circumstances, the minimum fee can be waived. Additionally,
certain legacy clients are billed at a fee rate different than the standard fee rate included above.
Employees of HIG and their immediate family receive a preferred investment management fee.
Many investment management client relationships predated the implementation of HIG’s current
fee schedule, and these clients generally have investment advisory agreements with fee
schedules they agreed to during the legacy arrangement. For this reason, clients’ fees in some
cases are higher or lower than those reflected in the foregoing schedule or are subject to
additional or differing terms, such as a different minimum fee than the current fee schedule.
Additional Information: Hillfolio, Hill, Hilltop Family Office
Investment advisory fees are based on the period-ending market value of client accounts
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(the last day of the month in the prior period) as provided by third-party sources. Accrued
interest, margin loan balances, and cash are usually included as a part of billable assets.
Cash is considered an asset class and managed as a part of the portfolio. Note, in
some low-interest-rate environments, HIG’s advisory fee may exceed the yield on cash.
Occasionally cash is temporarily held for a specific purpose (ex: tax payments) and
excluded from billing. Note that billing on margin loan balances presents a conflict of
interest: because HIG earns a higher fee, there is a disincentive to encourage clients to trim
or eliminate margin balances.
Client account balances on which HIG calculates fees may vary slightly from custodial
statements due to differences in accrued interest calculations between the custodian and the
account reporting software.
All fees are calculated as described above and are not charged based on a share of capital gains
upon or capital appreciation of an advisory client’s funds.
HIG will request authority from the client to receive payments directly from the client's account
held by an independent custodian. Clients provide written limited authorization to HIG
withdraw fees from the account.
Unearned fees are refunded when a client terminates their relationship with HIG. A client
agreement may be canceled at any time, by either party, for any reason with 30 days written
notice. 30 days after written notice will be considered the official termination date. Upon
termination of any account, prepaid, unearned fees are promptly refunded pro rata.
All fees paid to HIG are separate and distinct from the fees and expenses charged by ETFs and
mutual funds to their shareholders. These fees and expenses are described in each fund's
prospectus. These fees will generally include a management fee, other fund expenses, and a
possible distribution fee. A client could invest in ETFs or mutual funds directly, without the
services of HIG. In that case, the client would not receive the services provided by HIG which are
designed, among other things, to assist the client in determining which ETFs or mutual funds
are most appropriate to each client's financial condition and objectives. DFA, Bridgeway, Avantis
and AQR funds also may not be available to the client directly. Accordingly, the client should
review both the fees charged by the funds and the fees charged by HIG to fully understand the
total amount of fees to be paid by the client and to thereby evaluate the advisory services being
provided.
HIG’s fees are separate from brokerage commissions and transaction fees. Clients may incur
certain charges imposed by custodians, brokers, and other third parties such as custodial fees,
account maintenance fees, transaction fees, deferred sales charges, odd-lot differentials, transfer
taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and
securities transactions. Such charges, fees and commissions are exclusive of and in addition to
HIG’s fee. HIG and its supervised persons do not receive any portion of these commissions, fees or
costs and are not compensated for the sale of securities
As described in Item 4 Advisory Business, clients do not pay fees or brokerage commissions or to
Schwab as part of Institutional Intelligent Portfolios®. Schwab receives other revenue in
connection with of Institutional Intelligent Portfolios®, as described in this Disclosure Brochure.
Brokerage arrangements are further described below in Item 12 Brokerage Practices.
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For Retirement Account Clients (including ERISA plans, ERISA plan participants, and IRAs),
there may be other conflicts of interest that arise, and which require HIG to adhere to the
terms of a statutory or regulatory prohibited transaction exemption (“PTE”), such as PTE 77-4
or PTE 2020-02, in order to enter into a transaction with or on behalf of the Retirement
Account Client. For example, a conflict arises if HIG recommends a rollover or other transfer
of account to a Retirement Account Client resulting in the payment of a fee to HIG. HIG relies
on PTE 2020-02 in this case to mitigate the conflict.
For certain clients, we charge an advisory fee for services provided to the held-away
accounts mentioned above in Item 4, just as we do with client accounts held at our
primary custodians(s). The specific fee schedule is provided in the client’s investment
advisory agreement with us.
Longview Advantage ETF
Investors in the Longview Advantage ETF pay expenses in addition to fund-level management
fees. These expenses generally include administration, organizational, research and investment
expenses, such as brokerage commissions, legal, line of credit, director, accounting, audit and
other professional fees and expenses. For additional detail on these fees and expenses, please
refer to the Longview Advantage ETF’s offering documents.
HIG may, subject to the consent of the relevant client, invest client assets in the Longview
Advantage ETF. Client assets invested in the Longview Advantage ETF will initially be subject to
both an advisory fee payable to HIG with respect to their advisory account, and the Longview
Advantage ETF’s fees and expenses. However, the amount of any fund-level management fee
paid by HIG clients with respect to their assets invested in the Longview Advantage ETF will be
offset against the advisory fee paid to HIG by such clients. As such, the total advisory fee paid by
clients to HIG in a particular quarter will be reduced by the amount of any management fee
received by HIG from the Longview Advantage ETF with respect to such invested client assets for
such quarter, calculated on the basis of the client’s assets invested in the Longview Advantage
ETF as of the last day of the prior period.
For example, a hypothetical client with an account value of $1M with HIG who has $100,000
invested in the ETF as of the close of the relevant quarter would be charged as follows. Assuming
a management fee of 85bps, at the beginning of the next quarter, HIG would charge the client
$1,000,000 * 0.85% / 4, giving an initial management fee of $2,125 for that quarter. Assuming an
advisory fee of 0.15% to the Longview Advantage ETF, the management fee would be reduced by
the advisory fee for the $100,000 invested in the Longview Advantage ETF. As such the actual fee
charged would be $900,000 * 0.85% / 4 + $100,000 * (0.85%-0.15%)/4 = $2,087.50. The
adjustment for the Longview Advantage ETF advisory fee will not be increased or reduced to
reflect any intra-quarter rebalancing of invested assets. Fees for a new client investment
during a quarter will be calculated on a pro-rata basis.
HIG does not receive additional compensation on client assets that are invested in the Longview
Advantage ETF.
Credit and Cash Management Solutions
HIG offers clients the option of obtaining certain financial solutions from unaffiliated third-
party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ,
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Inc. and its affiliates, “UPTIQ”) and Flourish Financial LLC (“Flourish”). Focus Financial Partners,
LLC (“Focus”) is a minority investor in UPTIQ, Inc. UPTIQ is compensated by sharing in the
revenue earned by such third-party financial institutions for serving our clients. Although the
revenue paid to UPTIQ benefits UPTIQ Inc.’s investors, including Focus, our parent company, no
Focus affiliate will receive any compensation from UPTIQ or Flourish that is attributable to our
clients’ transactions.
Further information on this conflict of interest is available in Item 10 of this Brochure.
Focus Risk Solutions
HIG helps our clients obtain certain insurance solutions by introducing clients to our affiliate,
Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus
Financial Partners, LLC. FRS assists our clients with regulated insurance sales activity by
advising our clients on insurance matters and placing insurance products for them and/or
referring our clients to certain third-party insurance brokers (the “Brokers”), with whom FRS has
agreements, which either separately or together with FRS place insurance products for them. FRS
does not receive any compensation from the Brokers or any other third parties for serving our
clients. Additionally, in exchange for allowing certain of the Brokers to offer their services to clients
of other Focus firms, FRS receives periodic fees (the “Platform Fees”) from such Brokers. The
Platform Fees are expected to change over time. Such Platform Fees are revenue for FRS and,
ultimately, for our common parent company, Focus, but we do not share in such revenue and no
portion of the Platform Fees is attributable to our clients’ use of the Brokers’ services. Further
information on this service is available in Item 10 of this Brochure.
The federal and state securities laws impose liability under certain circumstances on
investment advisers even when acting in good faith, and nothing in this Agreement shall waive
or limit any rights that you may have under those laws. Except as otherwise provided by law,
neither we nor any of our employees, affiliates, representatives or agents shall be liable for: (a)
any investment loss that you may suffer by reason of any investment decision made or not
made or any other action taken or omitted in good faith by us with that degree of care, skill,
prudence, and diligence that a person acting in a fiduciary capacity would use under the
circumstances; (b) any loss arising from our adherence to your written and/or oral
instructions; (c) any act or failure to act by the Custodian, any Broker-Dealer to which we direct
transactions for the Account, or by any other
non-party to this Agreement; and/or (d) any loss that you may suffer by reason of any decision
made or other action taken by any External Manager.
As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations
imposed on us by the federal and state securities laws. As a result, you have certain rights that
you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted
as a limitation of our obligations under the federal and state securities laws or as a waiver of
any non-waivable rights you possess.
Item 6 – Performance-Based Fees and Side-By-Side Management
HIG does not charge any performance-based fees (fees based on a share of capital gains on or
capital appreciation of the assets of a client). All fees are calculated as described above and are
not charged on the basis of income or capital gains or capital appreciation of any portion of the
funds of an advisory client.
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Item 7 – Types of Clients
HIG manages investment portfolios for investment companies registered under the Investment
Company Act, individuals, families, trusts, ERISA plans (also known as qualified retirement plans),
trusts, institutions and small businesses.
HIG generally requires a minimum of $300,000 in investable assets, or a minimum annual fee of
$2,550 for financial planning services. The minimum account balance to enroll in the tax-loss
harvesting feature of Schwab Institutional Intelligent Portfolios® is $50,000.
HIG generally requires a minimum of $2,000,000 in investable assets for Hill wealth
management services, or a minimum annual fee of $17,000.
HIG offers Hilltop Family Office services based on a client’s complexity. The minimum fee for
Hilltop advanced planning services ranges from $10,000 to $50,000 per quarter and may be
charged in addition to investment management fees. The advanced planning fee may be waived
depending on investment management assets. The fee is collected quarterly, in advance,
reassessed annually.
HIG generally requires a minimum annual fee for Hill Institutional of $5,000, which includes
investment management and education services.
Item 8 – Methods of Analysis, Investment Strategies, Risk of Loss
Methods of Analysis and Investment Strategy
HIG's services are based on long-term investment strategies incorporating the principles of
Modern Portfolio Theory. HIG's investment approach is rooted in the belief that markets are
"efficient" over long periods of time and that investors' long-term returns are determined
principally by asset allocation decisions rather than market timing or stock picking. For clients’
allocations, HIG recommends diversified portfolios, principally using diversified, rules-based
mutual funds and/or ETFs, including the Longview Advantage ETF. HIG selects or recommends
portfolios of securities, principally broadly traded open end mutual funds, ETFs, or investment
grade fixed income securities to implement this investment strategy. For ETFs that HIG advises
on, HIG also recommends diversified, rules-based portfolios, but invests in individual stocks
rather than ETFs or open end mutual funds.
Although all investments involve risk, HIG's investment advice seeks to limit risk through
broad diversification among asset classes. HIG's investment philosophy is designed for
investors who desire a buy-and-hold strategy. Frequent securities trading increases brokerage
and other transaction costs that HIG's strategy seeks to minimize. HIG’s strategies do not use
securities that we believe classify as having any unusual risks.
Clients may hold or retain securities not recommended by HIG in the accounts where HIG has
discretion. Non-recommended securities with significant unrealized capital gains may be held
in a client’s account for tax reasons. If securities in the client’s account are held at the
instruction of the client and are not acquired or maintained according to HIG’s
recommendation, the client acknowledges that HIG has not reviewed, investigated or examined
these non-recommended securities and that HIG hereby disclaims any responsibility for the
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client’s investment decisions with respect to these securities. HIG can incorporate and manage
non-recommended securities or assets as a part of the client’s overall portfolio and risk profile
as part of its services. HIG is compensated for advice regarding such assets through its
standard fee schedule.
HIG receives supporting research from third parties, including experts affiliated with DFA,
Vanguard, AQR, Schwab, Fidelity, Bridgeway, Avantis among others. HIG uses funds offered by
DFA, Vanguard, AQR, Schwab, Fidelity, Bridgeway, Avantis and others in client portfolios. DFA,
Vanguard, AQR, Schwab, Fidelity, Bridgeway, and Avantis may provide historical market
analysis, risk/return analysis, and continuing education to HIG.
Analysis of a Client’s Financial Situation
In developing investment plans for clients, including recommending an appropriate asset
allocation, HIG relies on an analysis of the client’s financial objectives, current and estimated
future income and assets, and tolerance for risk. HIG may use a Monte Carlo simulation, a
standard statistical approach for dealing with uncertainty, to derive a recommended asset
allocation. As with any other methods used to make projections into the future, there are
several risks associated with this method, which may result in the client being unable to
achieve their financial goals. They include but are not limited to:
§ The risk that expected future cash flows will not match those used in the analysis,
§ The risk that future rates of return will fall short of the estimates used in the simulation,
§ The risk that inflation will exceed the estimates used in the simulation,
§ The risk that tax rates will be higher than was assumed in the analysis,
§ The risk that expected future savings rates will not match those used in the analysis.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. All
investments present the risk of loss of principal—the risk that the value of securities (mutual
funds, ETFs and individual stocks or bonds), when sold, may be less than the price paid for the
securities. Even if the value of the securities when sold is greater than the price paid, there is
the risk that the appreciation will be less than inflation. In other words, the purchasing power of
the proceeds may be less than the purchasing power of the original investment.
The mutual funds and ETFs HIG recommends or manages may include domestic and
international equities, publicly traded real estate investment trusts (REITs), and corporate and
government fixed income securities. Equity securities may include large, medium and small
capitalization stocks.
Mutual funds and ETFs invested in fixed income securities are subject to the same interest
rate, inflation and credit risks associated with the underlying bond holdings.
Among the riskiest mutual funds used in HIG’s investment strategies funds are the U.S. and
International small capitalization value funds, and emerging markets funds. Conservative fixed
income securities have lower risk of loss of principal, but most bonds (except Treasury Inflation
Protected Securities, or TIPS) present the risk of loss of purchasing power through inflation. This
risk is greatest for longer-term bonds.
Certain funds used by HIG may contain international securities. Investing outside the United
States involves risks, such as currency fluctuations, periods of illiquidity and price volatility.
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These risks may be greater with investments in developing countries. More information about
the risks of any particular market sector can be reviewed in the respective fund prospectus.
Cybersecurity
The computer systems, networks and devices used by HIG and service providers to us and our
clients to carry out routine business operations employ a variety of protections designed to
prevent damage or interruption from computer viruses, network failures, computer and
telecommunication failures, infiltration by unauthorized persons and security breaches.
Despite the various protections utilized, systems, networks, or devices potentially can be
breached. A client could be negatively impacted as a result of a cybersecurity breach.
Cybersecurity breaches can include unauthorized access to systems, networks, or devices;
infection from computer viruses or other malicious software code; and attacks that shut down,
disable, slow, or otherwise disrupt operations, business processes, or website access or
functionality. Cybersecurity breaches may cause disruptions and impact business operations,
potentially resulting in financial losses to a client; impediments to trading; the inability by us
and other service providers to transact business; violations of applicable privacy and other
laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation
costs, or additional compliance costs; as well as the inadvertent release of confidential
information.
Similar adverse consequences could result from cybersecurity breaches affecting issuers of
securities in which a client invests; governmental and other regulatory authorities; exchange and
other financial market operators, banks, brokers, dealers, and other financial institutions; and
other parties. In addition, substantial costs may be incurred by these entities to prevent any
cybersecurity breaches in the future.
Item 9 – Disciplinary Information
Registered investment advisors are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of HIG or the integrity of HIG’s
management. HIG has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Focus Financial Partners
As noted above in response to Item 4, certain investment vehicles affiliated with CD&R
collectively are indirect majority owners of Focus LLC, and certain investment vehicles affiliated
with Stone Point are indirect owners of Focus LLC. Because HIG is an indirect, wholly-owned
subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of HIG.
Longview Advantage ETF
HIG is the investment adviser to Longview Advantage ETF, which HIG recommends for
investment in client accounts. Please refer to HIG’s discussion of Longview Advantage ETF in
various places throughout this Brochure. Please also refer to the Longview Advantage ETF
prospectus for more information at https://longviewresearchpartners.com/.
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HIG does recognize the conflicts of interest in recommending Longview Advantage ETF to HIG’s
clients, including:
§
“Steering” client assets into Longview Advantage ETF makes the investment more
attractive to the public with respect to asset-raising efforts;
§ Growth in the Longview Advantage ETF allows for spreading of costs over a larger
§
asset base; and
In selecting Longview Advantage ETF for a client’s accounts we are, by definition,
not selecting another ETF which is unaffiliated with HIG, and which may have a
lower management fee or may achieve (or may have already achieved) greater
recent performance returns.
HIG addresses this conflict by only investing a portion of HIG clients’ assets in the Longview
Advantage ETF based on HIG’s reasonable belief that the investment is in the best interest of
the clients and fully and fairly disclosing the material facts regarding this relationship to
clients, including in this Brochure.
Credit and Cash Management Solutions
We offer clients the option of obtaining certain financial solutions from unaffiliated third-party
financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc.
and its affiliates, “UPTIQ”) and Flourish Financial, LLC (“Flourish”). These third-party financial
institutions are banks and non-banks that offer credit and cash management solutions to our
clients, as well as certain other unaffiliated third parties that provide administrative and
settlement services to facilitate UPTIQ’s cash management solutions. UPTIQ acts as an
intermediary to facilitate our clients’ access to these credit and cash management solutions.
Flourish acts as an intermediary to facilitate our clients’ access to cash management solutions.
We are a wholly owned subsidiary of Focus Financial Partners, LLC (“Focus”). Focus is a minority
investor in UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by such
third-party financial institutions for serving our clients. Although the revenue paid to UPTIQ
benefits UPTIQ Inc.’s investors, including Focus, no Focus affiliate will receive any compensation
from UPTIQ that is attributable to our clients’ transactions. Additionally, no Focus affiliate will
receive any compensation from Flourish that is attributable to our clients’ transactions.
For services provided by UPTIQ and Flourish to clients of other Focus firms and when legally
permissible, UPTIQ and Flourish each shares a portion of this earned revenue with our affiliate,
Focus Solutions Holdings, LLC (“FSH”). Such compensation to FSH is also revenue for FSH’s and
our common parent company, Focus. This compensation to FSH does not come from credit or
cash management solutions provided to any of our clients. However, the volume generated by
our clients’ transactions allows Focus to negotiate better terms with UPTIQ and Flourish, which
benefits Focus. We mitigate this conflict by: (1) fully and fairly disclosing the material facts
concerning the above arrangements to our clients, including in this Brochure; and (2) offering
UPTIQ’s and Flourish’s solutions to clients on a strictly nondiscretionary and fully disclosed
basis, and not as part of any discretionary investment services. Additionally, we note that
clients who use UPTIQ’s and Flourish’s services will receive product-specific disclosure from the
third-party financial institutions and other unaffiliated third-party intermediaries that provide
services to our clients.
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We have an additional conflict of interest when we recommend credit solutions to our clients
because our interest in continuing to receive investment advisory fees from client accounts
gives us a financial incentive to recommend that clients borrow money rather than liquidate
some or all of the assets we manage.
Credit Solutions
Clients retain the right to pledge assets in accounts generally, subject to any restrictions
imposed by clients’ custodians. While credit solution programs that we offer facilitate secured
loans through third-party financial institutions, clients are free instead to work directly with
institutions outside such programs. Because of the limited number of participating third-party
financial institutions, clients may be limited in their ability to obtain as favorable loan terms as
if the client were to work directly with other banks to negotiate loan terms or obtain other
financial arrangements.
Clients should also understand that pledging assets in an account to secure a loan involves
additional risk and restrictions. A third-party financial institution has the authority to liquidate
all or part of the pledged securities at any time, without prior notice to clients and without their
consent, to maintain required collateral levels. The third-party financial institution also has the
right to call client loans and require repayment within a short period of time; if the client cannot
repay the loan within the specified time period, the third-party financial institution will have the
right to force the sale of pledged assets to repay those loans. Selling assets to maintain
collateral levels or calling loans may result in asset sales and realized losses in a declining
market, leading to the permanent loss of capital. These sales also may have adverse tax
consequences. Interest payments and any other loan-related fees are borne by clients and are in
addition to the advisory fees that clients pay us for managing assets, including assets that are
pledged as collateral. The returns on pledged assets may be less than the account fees and
interest paid by the account. Clients should consider carefully and skeptically any
recommendation to pursue a more aggressive investment strategy in order to support the cost
of borrowing, particularly the risks and costs of any such strategy. More generally, before
borrowing funds, a client should carefully review the loan agreement, loan application, and other
forms and determine that the loan is consistent with the client’s long-term financial goals and
presents risks consistent with the client’s financial circumstances and risk tolerance.
We use UPTIQ to facilitate credit solutions for our clients.
Cash Management Solutions
For cash management programs, certain third-party intermediaries provide administrative and
settlement services to our clients. Engaging the third-party financial institutions and other
intermediaries to provide cash management solutions does not alter the manner in which we
treat cash for billing purposes. Clients should understand that in rare circumstances,
depending on interest rates and other economic and market factors, the yields on cash
management solutions could be lower than the aggregate fees and expenses charged by the
third-party financial institutions, the intermediaries referenced above, and us. Consequently, in
these rare circumstances, a client could experience a negative overall investment return with
respect to those cash investments. Nonetheless, it might still be reasonable for a client to
participate in a cash management program if the client prefers to hold cash at the third-party
financial institutions rather than at other financial institutions (e.g., to take advantage of FDIC
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insurance).
We use UPTIQ and Flourish to facilitate cash management solutions for our clients.
Focus Risk Solutions
We help clients obtain certain insurance products from unaffiliated insurance companies by
introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary
of our parent company, Focus Financial Partners, LLC (“Focus”). FRS acts as an intermediary to
facilitate our clients’ access to insurance products. FRS has agreements with certain third-
party insurance brokers (the “Brokers”) under which the Brokers assist our clients with
regulated insurance sales activity.
Neither we nor FRS receives any compensation from the Brokers or any other third parties for
providing insurance solutions to our clients. For services provided by FRS to clients of other
Focus firms, FRS receives a percentage of the upfront commission or a percentage of the
ongoing premiums for policies successfully placed with insurance carriers on behalf of referred
clients. Additionally, in exchange for allowing certain of the Brokers to offer their services to
clients of other Focus firms, FRS receives periodic fees (the “Platform Fees”) from such Brokers.
The Platform Fees are expected to change over time. Such Platform Fees are revenue for FRS and,
ultimately, for our common parent company, Focus, but we do not share in such revenue and no
portion of the Platform Fees is attributable to our clients’ use of the Brokers’ services. Such
compensation to FRS, including the Platform Fees, is also revenue for our common parent
company, Focus Financial Partners, LLC. However, this compensation to FRS does not come from
insurance solutions provided to any of our clients. The volume generated by our clients’
transactions does benefit FRS and Focus in attracting, retaining, and negotiating with the
Brokers and insurance carriers. We mitigate this conflict by: (1) fully and fairly disclosing the
material facts concerning the above arrangements to our clients, including in this Brochure; (2)
offering FRS solutions to clients on a strictly nondiscretionary and fully disclosed basis, and not
as part of any discretionary investment services; and (3) not sharing in any portion of the
Platform Fees. Additionally, we note that clients who use FRS’s services will receive product-
specific disclosure from the Brokers and insurance carriers and other unaffiliated third-party
intermediaries that provide services to our clients.
The insurance premium is ultimately dictated by the insurance carrier, although in some
circumstances the Brokers or FRS may have the ability to influence an insurance carrier to
lower the premium of the policy. The final rate may be higher or lower than the prevailing
market rate. We can offer no assurances that the rates offered to you by the insurance carrier
are the lowest possible rates available in the marketplace.
Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
HIG has adopted a Code of Ethics for all supervised persons of the firm, which emphasizes the
firm's commitment to ethical conduct. HIG's Code of Ethics describes the firm's standard of
business conduct, fiduciary duties and responsibilities to clients. The Code of Ethics sets forth
HIG's practice of supervising the personal securities transactions of employees with access to
client information. Individuals associated with HIG may buy or sell securities for their personal
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accounts that are identical to and/or different from those recommended to clients. It is the
expressed policy of HIG that no person employed by the firm shall prefer his or her own interest
to that of an advisory client or make personal investment decisions based on the investment
decisions of advisory clients.
To supervise compliance with its Code of Ethics, HIG requires that anyone associated with this
advisory practice with access to advisory recommendations provide quarterly securities holding
reports and transaction reports to the firm's principal. HIG also requires such access persons to
receive approval from the Chief Compliance Officer prior to investing in any IPO's or private
placements (limited offerings).
HIG's Code of Ethics further includes the firm's policy prohibiting the use of material non-
public information and protecting the confidentiality of client information. HIG requires that all
individuals must act in accordance with all applicable federal and state regulations governing
registered investment advisory practices. Any individual not in observance of the above may be
subject to discipline.
It is HIG’s policy that the firm will not affect any principal or agency cross securities transactions
for client accounts. Adviser will also not cross trades between client accounts.
HIG will provide a complete copy of its Code of Ethics to any client or prospective client upon
request. To request a copy, please contact Nell Schiffer at (314) 448-4023.
Item 12 – Brokerage Practices
Investment Management Services: Hillfolio, Hill, Hilltop Family Office
HIG receives services that it would not receive if it did not offer investment advice and use
Schwab, and Fidelity as custodians. The services include brokerage, custody, research, practice
management resources, education, technology, and access to mutual funds and other
investments that otherwise would require a significantly higher minimum initial investment.
These relationships pose an inherent conflict.
To minimize any conflicts, HIG regularly reviews brokerage programs to ensure that HIG’s
recommendations are consistent with its fiduciary duty to achieve best execution. The Schwab or
Fidelity brokerage program will generally be recommended to advisory clients for the execution of
mutual fund and equity securities transactions, though HIG does have brokerage relationships
with other custodians. These trading platforms are essential to HIG’s service arrangements and
capabilities.
HIG participates in the Schwab Advisor Services (SAS) program offered to independent
investment advisors by Charles Schwab & Company, Inc. (“Schwab”). Through Schwab Advisor
Services, Schwab provides HIG and our clients with institutional brokerage services, trading,
custody, reporting and related services – many of which are not typically available to Schwab
retail customers. Schwab is a FINRA member broker dealer.
HIG participates in the Fidelity Institutional® program offered to independent investment
advisors by Fidelity Investments. Through Fidelity Institutional®, Fidelity provides HIG and our
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clients with institutional brokerage services, trading, custody, reporting and related services –
many of which are not typically available to Fidelity retail customers. Fidelity is a FINRA
member broker dealer.
As discussed in Item 4, HIG contracts Schwab for the technology platform and related trading and
account management services for some accounts through Institutional Intelligent Portfolios®.
Clients do not pay brokerage commissions or any other fees to Schwab as part of Intelligent
Portfolios®.
HIG recommends the use of fixed income funds as opposed to individual fixed income securities
for most clients. However, HIG can purchase individual fixed income securities when it is best
for the client. HIG exercises authority to arrange client transactions in fixed income securities.
The reasonableness of brokerage costs, commissions and markup/mark downs is based on the
broker dealer's ability to provide professional services, competitive execution, and other
services that will help HIG provide investment management services to clients. Client trades in
fixed income securities may be aggregated with trades for other advisory clients to achieve
better pricing and commission costs. All trades, including for fixed income, are allocated in the
client's best interest as set forth in HIG's policy and procedures manual. Where there is a limited
supply of a security, HIG will allocate investment opportunities among its clients in a fair and
reasonable manner.
Should HIG decide that aggregating client orders (block trading) for more than one client is in
the best interests of those clients, then HIG will affect the transaction and allocate shares from
the block trade in a fair and equitable manner.
Under certain circumstances, employees of HIG may participate in the aggregated trade of
securities alongside clients of HIG. This will be covered in the Code of Ethics section of the
Policies and Procedures manual. Employees of HIG will not be favored as far as price or
allocations in this type of transaction are concerned.
HIG does not have any arrangements to compensate any broker-dealer for client referrals. HIG
does not have any soft dollar arrangements.
HIG may also recommend no-load annuity products and other specialty products, for which HIG
receives no commission or other sales-related compensation.
When trading client accounts, errors may periodically occur. HIG does not retain any client
trade error gains. HIG makes clients whole with respect to any trade error losses incurred by
the client and caused by HIG, full policy may be requested from HIG’s Policies and Procedures
manual.
HIG seeks to ensure that clients and prospective clients have full and fair disclosure of all
material facts about these relationships so that clients can properly evaluate conflicts. As
such, clients are deemed to have consented to these conflicts if they choose to retain HIG’s
services.
Hill Institutional
HIG does not arrange for the execution of securities transactions for plans as a part of this
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service. Transactions are executed directly through employee plan participation. Assets are
custodied at Ascensus Trust or ADP.
Directed Brokerage
Most of our clients custody their assets with broker-dealer custodians that we recommend and
with whom we have an institutional relationship. However, under certain circumstances, we are
willing to permit clients to direct HIG in writing to use a particular broker-dealer that HIG does
not recommend to execute some or all of their transactions. In these instances, the client will
negotiate terms and arrangements for their account with that broker-dealer, and HIG will not
be able to negotiate commissions on the client’s behalf and will not be able to aggregate trades
with trades of other clients. As a result, is possible that clients with directed brokerage
arrangements will not receive best execution since this arrangement could result in higher
commissions, greater spreads, less favorable net prices, and less favorable execution prices.
Item 13 – Review of Accounts
Hillfolio, Hill, Hilltop Family Office
Account assets are supervised regularly and reviewed periodically by the trading team and lead
advisors, but not less than annually. The review process contains each of the following elements:
§ assessing client goals and objectives;
§ evaluating the employed strategy(ies);
§ monitoring the portfolio(s); and
§ addressing the need to rebalance.
Additional non-periodic account reviews may be triggered by any of the following events:
§ a specific client request;
§ a change in client goals and objectives;
§
tax loss harvesting opportunities;
§ an imbalance in a portfolio asset allocation; and
§ market/economic conditions.
Clients also receive monthly statements from their account custodian, which will outline the
client's current positions and current market value. Some clients receive quarterly performance
reports that summarize the client's account and asset allocation.
Hill Institutional
Plan assets are reviewed periodically by the trading team and lead advisors, but not less than
annually, according to the standards and situations described above for investment management
accounts.
Hill Institutional accounts receive quarterly statements from the custodian. HIG may
provide additional reports and recommendations to plan sponsors based on its review of
plan asset performance or specific client requests.
Longview Advantage ETF
In addition to periodic review by the trading team and lead advisors, the portfolio and trading
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activity of the Longview Advantage ETF is also subject to review and oversight by its board of
Trustees.
Item 14 – Client Referrals and Other Compensation
As indicated under the disclosure for Item 12, Schwab and Fidelity may provide HIG with access
to services generally available only to institutional investors. The services include brokerage,
custody, research, practice management resources, education, and access to mutual funds and
other investments that otherwise would require a significantly higher minimum initial
investment. HIG is exempt from paying fees for these services with Schwab because at least $10
million of client assets are held at Schwab.
These services benefit HIG but may not benefit its clients’ accounts. Many of the products and
services assist HIG in managing and administering clients’ accounts. These include software
and other technology that provide access to client account data (such as trade confirmations
and account statements), facilitate trade execution (and allocation of aggregated trade orders
for multiple client accounts), provide research, pricing information and other market data,
facilitate payment of HIG’s fees from its clients’ accounts, and assist with back-office
functions, recordkeeping and client reporting. Many of these services are used to service all or a
substantial number of HIG’s accounts.
Mutual fund companies and custodians; including but not limited to DFA, AQR, Bridgeway,
Avantis, Vanguard, Fidelity, and Schwab; provide continuing education for HIG personnel. These
companies may also make available to HIG other services intended to help HIG manage and
further develop its business enterprise. These services may include consulting, publications and
conferences on practice management, information technology, business succession, regulatory
compliance, and marketing. These services are designed to assist HIG plan and design its
services for clients.
These companies may occasionally pay for HIG employees’ continuing education which may
include conference admission, airfare, or hotel accommodations.
Clients should be aware that economic benefits from a custodian or mutual fund company
create a conflict of interest, as these benefits may influence HIG’s recommendation of this
custodian or mutual fund company over one that does not furnish similar services. HIG
attempts to mitigate this potential conflict by performing regular reviews of the services
provided by custodians and mutual fund companies, and by ensuring that clients are receiving
the best possible value.
HIG does not enter into any commitments with the brokers for transaction levels in exchange
for any services or products from brokers.
Through its web-based service, DFA may provide investor client referrals to HIG. DFA makes such
referrals to many investment advisors based on the geographic location of the prospective client
and minimum AUM levels. DFA is not compensated for these referrals by HIG. DFA does not
provide any other referral help to HIG.
HIG has arrangements with certain third parties, called promoters, under which such promoters
refer clients to us in exchange for a percentage of the advisory fees we collect from such referred
clients. Such compensation incentivizes the promoters to refer clients to us, which is a conflict
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of interest for the promoters. Rule 206(4)-1 under the Advisers Act addresses this conflict of
interest by, among other things, requiring disclosure of whether the promoter is a client or a
non-client and a description of the material conflicts of interest and material terms of the
compensation arrangement with the promoter. Accordingly, HIG requires promoters to disclose
to referred clients, in writing: whether the promoter is a client or a non-client; that the promoter
will be compensated for the referral; the material conflicts of interest arising from the
relationship and/or compensation arrangement; and the material terms of the compensation
arrangement, including a description of the compensation to be provided for the referral.
HIG’s parent company is Focus Financial Partners, LLC (“Focus”). From time to time, Focus
holds partnership meetings and other industry and best-practices conferences, which typically
include HIG, other Focus firms and external attendees. These meetings are first and foremost
intended to provide training or education to personnel of Focus firms, including HIG. However,
the meetings do provide sponsorship opportunities for asset managers, asset custodians,
vendors and other
third-party service providers. Sponsorship fees allow these companies to advertise their
products and services to Focus firms, including HIG. Although the participation of Focus firm
personnel in these meetings is not preconditioned on the achievement of a sales target for any
conference sponsor, this practice could nonetheless be deemed a conflict as the marketing
and education activities conducted, and the access granted, at such meetings and conferences
could cause HIG to focus on those conference sponsors in the course of its duties. Focus
attempts to mitigate any such conflict by allocating the sponsorship fees only to defraying the
cost of the meeting or future meetings and not as revenue for itself or any affiliate, including
HIG. Conference sponsorship fees are not dependent on assets placed with any specific
provider or revenue generated by such asset placement.
The following entities have provided conference sponsorship to Focus between January 1, 2024
and February 1, 2025:
• Advent Software, Inc. (includes SS&C)
• BlackRock, Inc.
• Blackstone Administrative Services Partnership L.P.
• Capital Integration Systems LLC (CAIS)
• Charles Schwab & Co., Inc.
• Confluence Technologies Inc.
• Eaton Vance Distributors, Inc. (includes Parametric Portfolio Associates)
• Fidelity Brokerage Services LLC and Fidelity Distributors Company LLC (includes
Fidelity Institutional Asset Management and FIAM)
• Flourish Financial LLC
• Franklin Distributors, LLC (includes O’Shaughnessy Asset Management, L.L.C. (OSAM)
and CANVAS)
• K&L Gates LLP
• Nuveen Securities, LLC
• Orion Advisor Technology, LLC
• Pinegrove Capital Partners LLC (includes Brookfield Oaktree Wealth Solutions)
• Practifi, Inc.
• Salus GRC, LLC
• Stone Ridge Asset Management LLC
• The Vanguard Group, Inc.
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• TriState Capital Bank
• UPTIQ, Inc.
You can access updates to the list of conference sponsors on Focus’ website through the following
link: https://focusfinancialpartners.com/conference-sponsors/
Item 15 – Custody
We are deemed to have custody of a client’s assets if the client authorizes us to deduct our
advisory fees directly from the client’s account and/or to perform third-party transfers.
Schwab, Fidelity, JP Morgan, Vanguard, Missouri MOST, or Utah 529 maintain actual custody of
clients’ assets. The Longview Advantage ETF utilizes U.S. Bank, N.A. as its custodian.
Clients should receive at least quarterly statements from the broker dealer, bank or other
qualified custodian that holds and maintains client’s investment assets. HIG urges clients to
carefully review such statements and compare such official custodial records to the account
statements that we may provide to you. HIG’s statements may vary from custodial statements
based on accounting procedures, reporting dates, or valuation methodologies of certain
securities.
Item 16 – Investment Discretion
Investment management clients are requested to provide HIG with written authority to
determine which securities, and the amounts of securities, that are bought or sold. Any
reasonable limitations on discretionary authority shall be included in the client’s advisory
agreement or added as an addendum. Clients may change or amend these limitations at any
time. Such amendments shall be submitted in writing. HIG reserves the right, in its sole
discretion, to reject any such restrictions.
For ERISA plans custodied at Ascensus or ADP, HIG serves as the ERISA 3(21) fiduciary advisor to
the Plan. HIG consults with the Trustees on all aspects of the Plan, assists in building model
portfolio allocations and choosing investment options for the Plan, and provides advice to
participants. HIG has non-discretionary authority - meaning the client retains and exercises the
final decision-making authority for implementing or rejecting HIG’s recommendations.
For ERISA plans, individual retirement accounts, or institution accounts custodied at Schwab or
Fidelity, HIG serves as a fiduciary with discretionary authority - meaning HIG has the authority to
make the investment decisions in its sole discretion without the client’s prior approval. These
authorities are reflected in HIG’s Investment Advisory Agreement.
Item 17 – Voting Client Securities
Hillfolio; Hilltop Family Office; Hill Investment Group; Hill Institutional
With respect to its Hillfolio, Hilltop Family Office, Hill Investment Group, and Hill Institutional
service lines, HIG does not accept the authority to vote proxies on behalf of new clients and only
votes client proxies for certain legacy clients.
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Clients should note that HIG will neither advise nor act on behalf of the client in legal
proceedings involving companies whose securities are held or previously were held in the
client’s account(s), including, but not limited to, the filing of “Proofs of Claim” in class action
settlements or bankruptcies. If desired, clients may direct HIG to transmit copies of class
action notices to the client or a third party. Upon such direction, HIG will make commercially
reasonable efforts to forward such notices in a timely manner.
Clients enrolled in Schwab’s Institutional Intelligent Portfolios® program designate Schwab to
vote proxies for the funds held in their accounts.
Longview Advantage ETF
In connection with the provision of investment advisory services, HIG has been granted proxy
voting responsibility on behalf of the Longview Advantage ETF. In exercising proxy voting
discretion, HIG is guided by general fiduciary principles to act prudently and in the best interest
of its client.
HIG has adopted a proxy voting policy and procedures with respect to the Longview
Advantage ETF (the “ETF Proxy Voting Procedures”), as described below. HIG has appointed
Egan-Jones Proxy Service (the “Proxy Voting Service”) to provide proxy voting services to HIG,
including in-depth research, voting recommendations, vote execution, and recordkeeping.
HIG relies on pre-populated and/or automated voting, which means the Proxy Voting Service will
automatically populate the proxy voting system in accordance with the Proxy Voting Service’s
benchmark guidelines (the “Guidelines”). For those proxy proposals with a default policy
position, the votes will be cast as populated in the system by the Proxy Voting Service unless
directed otherwise by HIG. For those proxy proposals without a default policy position, the votes
will be cast as populated in the system by HIG.
HIG acknowledges that conflicts of interest can arise which can affect how HIG votes proxies.
HIG seeks to address conflicts of interest through the establishment of voting positions in
accordance with the Guidelines. HIG believes that the default application of the Guidelines
should, in most cases, adequately address conflicts of interest. HIG will also monitor the Proxy
Voting Service in order to ensure the Proxy Voting Service’s conflicts of interest, if any, are
properly disclosed and addressed. Where HIG identifies such a conflict of interest it may
assume responsibility for voting the proxy, and after analysis in accordance with the ETF Proxy
Voting Procedures, communicate such voting decision to the Proxy Voting Service.
For situations where HIG votes proxies outside of the Guidelines, HIG will determine whether or
not there is a conflict of interest that may affect HIG’s exercise of voting discretion. Where HIG
identifies such a conflict of interest, it will employ such strategy or strategies as it deems
appropriate to mitigate such conflict, including but not limited to:
-
-
“Overriding” the Proxy Voting Service’s vote instruction or otherwise instructing the
Proxy Voting Service to vote in a certain way that is, in HIG’s judgment, consistent with
the client’s best interest; or
Informing the client of the conflict and deferring to the client’s direction as to how the
proxy should be voted.
A copy of HIG’s proxy voting policies will be provided to HIG’s clients or prospective clients upon
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receipt of a written request.
Item 18 – Financial Information
HIG does not require the prepayment of fees of $1,200 or more, six months or more in advance,
and as such is not required to file a balance sheet. HIG has no financial commitment that
impairs its ability to meet contractual and fiduciary commitments to clients and has not been
the subject of a bankruptcy proceeding.
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