HILLTOP WEALTH & TAX SOLUTIONS

Item 1: Cover Page Item 1: Cover Page Part 2A of Form ADV Firm Brochure November 17, 2025 Hilltop Partners, LLC dba Hilltop Wealth & Tax Solutions dba Hilltop Wealth Solutions SEC No. 801-115255 Main Office 4100 Edison Lakes Parkway, Suite 225 Mishawaka, IN 46545 phone: 574-889-PLAN (7526) Branch Office 13420 Parker Commons Blvd., Suite 106 Ft. Myers, FL 33912 phone: 833-889-7526 email: erikbrenner@hilltopwealthtax.com website: www.hilltopwealthtax.com This brochure provides information about the qualifications and business practices of Hilltop Partners, LLC. If you have any questions about the contents of this brochure, please contact us at 574-889-7526. 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. Registration with the SEC or state regulatory authority does not imply a certain level of skill or expertise. Additional information about Hilltop Partners, LLC, is also available on the SEC’s website at www.adviserinfo.sec.gov. Page 1 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 2: Material Changes Item 2: Material Changes This Firm Brochure is our disclosure document prepared according to regulatory requirements and rules. Consistent with the rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business fiscal year. Furthermore, we will provide you with other interim disclosures about material changes as necessary. The following material change was made to this Brochure since the last annual update issued on February 27, 2025: ▪ The minimum fee for portfolio management services was increased from $4,500 to $6,250. Please see Item 5 of this Brochure for the firm’s current fees and compensation. ▪ Conflicts of interest regarding Erik Brenner’s ownership interest in Pinnacle Renewable Solutions and book authorship were added. Please see Item 10.C of this Brochure for information. Page 2 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 3: Table of Contents 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 Item 5: Fees and Compensation ............................................................................................................................ 9 Item 6: Performance-Based Fees and Side-by-Side Management ......................................................... 13 Item 7: Types of Clients ........................................................................................................................................... 14 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ................................................. 15 Item 9: Disciplinary Information ........................................................................................................................... 23 Item 10: Other Financial Industry Activities and Affiliations ........................................................................ 24 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................................................................................................................................................... 26 Item 12: Brokerage Practices ................................................................................................................................... 28 Item 13: Review of Accounts ................................................................................................................................... 35 Item 14: Client Referrals and Other Compensation ........................................................................................ 36 Item 15: Custody .......................................................................................................................................................... 37 Item 16: Investment Discretion ............................................................................................................................... 38 Item 17: Voting Client Securities ............................................................................................................................ 39 Item 18: Financial Information ................................................................................................................................ 40 Page 3 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 4: Advisory Business Item 4: Advisory Business A. Hilltop Partners, LLC Hilltop Partners, LLC, also known Hilltop Wealth & Tax Solutions or Hilltop Wealth Solutions (“Hilltop Wealth” or “the firm”), is an Indiana limited liability company. The firm is owned by Erik Brenner (75.1%) and Merchant Wealth Partners (24.9%). The firm has been providing investment advisory services since January 2018. B. Description of Advisory Services Offered Portfolio Management Services For its discretionary asset management services, Hilltop Wealth receives a limited power of attorney to effect securities transactions on behalf of its clients that include securities and strategies described in Item 8 of this brochure. Hilltop Wealth’s discretionary asset management services are predicated on the client's investment objectives, goals, tolerance for risk, and other personal and financial circumstances. Hilltop Wealth will analyze each client's current investments, investment objectives, goals, age, time horizon, financial circumstances, investment experience, investment restrictions and limitations, and risk tolerance and implement a portfolio consistent with such investment objectives, goals, risk tolerance and related financial circumstances Hilltop Wealth’s objective is to review the client’s tax, financial, and estate planning objectives and goals in connection with the client’s investment objectives, goals, tolerance for risk, and other personal and financial circumstances and make appropriate recommendations and implementation decisions. Hilltop Wealth may engage third-party service providers to assist with the tax and estate planning portion of the services provided to clients. In addition, Hilltop Wealth may utilize third-party software to analyze individual security holdings and separate account managers utilized within the client’s portfolio. Hilltop Wealth’s investment advisory services to clients take into account a client's personal financial circumstances, investment objectives and tolerance for risk (e.g., cash-flow, tax and estate). Hilltop Wealth’s engagement with a client will include, as appropriate, the following: ▪ Providing assistance in reviewing the client's current investment portfolio against the client's personal and financial circumstances as disclosed to Hilltop Wealth in response to a questionnaire and/or in discussions with the client and reviewed in meetings with Hilltop Wealth. ▪ Analyzing the client's financial circumstances, investment holdings and strategy, and goals. ▪ Providing assistance in identifying a targeted asset allocation and portfolio design. ▪ Implementing and/or recommending individual equity and fixed income securities, mutual funds and ETFs. Page 4 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 4: Advisory Business ▪ Reporting to the client on a quarterly basis or at some other interval agreed upon with the client, information on contributions and withdrawals in the client's investment portfolio, and the performance of the client's portfolio measured against appropriate benchmarks (including benchmarks selected by the client). ▪ Proposing changes in the client's investment portfolio in consideration of changes in the client's personal circumstances, investment objectives and tolerance for risk, the performance record of any of the client's investments, and/or the performance of any fund retained by the client. ▪ If the client’s portfolio and personal circumstances, investment objectives, and tolerance for risk make such advice appropriate, providing recommendations to hedge a client’s portfolio through the use of derivative strategies, to generate additional income through the use of covered call option writing strategies involving exchange listed or OTC options, and/or to monetize or hedge concentrated stock positions. In addition to providing Hilltop Wealth with information regarding their personal financial circumstances, investment objectives and tolerance for risk, clients are obligated to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio, and to promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. Hilltop Wealth will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. Hilltop Wealth will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. Retirement Plan Participant Account Management (Discretionary) We use a third-party platform (Pontera Order Management System) to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of client funds since we do not have direct access to client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the client allowing them to connect an account(s) to the platform. Once client account(s) is connected to the platform, we will review the current account allocations. When deemed necessary, we will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. We may provide these services or, alternatively, may arrange for the plan’s other providers to offer these services, as agreed upon between our firm and the client. Current market value of the plan will be added to the client’s existing assets under management and cumulative fee will be drawn from existing managed account in accordance with the published fee schedule. Page 5 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 4: Advisory Business Retirement Rollovers – Conflicts and Added Fees As a fee-based investment adviser, Hilltop Wealth (and its investment adviser representatives) makes more money either when your account assets grow or when you add money to your account. As a Plan participant, you may be paying little or nothing for the Plan’s investment services. As such, your costs are likely to be more post-rollover. We may compensate our investment professionals in a way that incrementally rewards them based on the level of aggregate revenue they generate for our firm. In this regard, we have policies and procedures for supervisory review to ensure we are advising you in a way that’s in your best interests. In addition, we conduct an annual review of rollover transactions to ensure our business practices are aligned in a manner that places your interests first. Such annual review is provided to a member of our executive team who certifies the firm’s compliance. We do not engage in sales contests, production awards, or related giveaways that inhibit our ability to provide advice that’s in your best interests. We regularly update our conflicts of interest and will update you accordingly on any material changes affecting our relationship with you. Comprehensive Financial Planning Services The client will receive a written or oral report (depending on the client’s preference) that provides the client with a detailed financial plan designed to help achieve the client’s stated financial goals and objectives. Based on the client’s needs, financial planning services generally include the following: ▪ Preparation of a consolidated assessment of financial condition, which may include: • Annual budgeting • Cash flow monitoring • Account reconciliations • Personal financial statement preparation • Debt management ▪ Establishment of objectives over relevant timeframes, which may include: • Retirement objectives • Philanthropy • Estate planning • Wealth transition • Other related issues ▪ Preparation of a recommended asset allocation that serves to diversify the client's portfolio among different categories of investments, such as: • Small, medium, and large capitalization securities • Corporate and government fixed income (short-, intermediate-, and long-term maturities) • Emerging market securities (i.e., foreign issuers) Page 6 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 4: Advisory Business • Such other asset categories that are suitable in light of the client's investment goals, objectives, and risk tolerance ▪ Preparation of a retirement plan that serves to identify whether the client is saving enough and investing in a way that meets retirement objectives in light of the client's financial circumstances and risk tolerance. ▪ Risk analysis and preparation of an insurance plan to meet the needs of the client, taking into account family, business, and other financial objectives of the client. ▪ Preparation of an estate plan to ensure that wealth transition, tax, and related issues are met in accordance with the client's wishes. In many instances, an outside attorney will need to be hired to handle specific legal issues that arise in the formation and implementation of an estate plan, which may include the following topics: • Estate planning • Estate administration • Charitable/philanthropic planning • Advice on wills and trust agreements • Business transition planning • Retirement and distribution planning Hilltop Wealth gathers required information through in-depth personal interviews and questionnaires. Information gathered includes the client's current financial status, investment objectives, future goals, and attitudes toward risk. Related documents supplied by the client are carefully reviewed, and a report is prepared covering one or more of the above-mentioned topics as directed by the client. Tax Preparation Services Hilltop Wealth may refer clients to its affiliate, Hilltop Tax Solutions, LLC (“Hilltop Tax”), for tax preparation and/or bookkeeping services. Services will be separately agreed upon between the client and Hilltop Tax, and Hilltop Tax will bill the client separately for services. Please see Item 10 of this Brochure for conflicts of interest. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs Hilltop Wealth does not participate in wrap fee programs, where brokerage commissions and transaction costs are included in the asset-based fee charged to the client. Page 7 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 4: Advisory Business E. Client Assets Under Management As of December 31, 2024, Hilltop Wealth had $465,957,187 of discretionary assets under management, and $24,857,338 of non-discretionary assets under management. Page 8 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 5: Fees and Compensation Item 5: Fees and Compensation A. Methods of Compensation and Fee Schedule Portfolio Management Fees Hilltop Wealth’s fee for the services is an asset-based fee calculated as a percentage of the value of the managed assets according to the following fee schedule, which represents the advisor’s maximum fees for individual services. All fees are negotiable. Account Asset Value Annual Management Fee First $250,000 Next $500,000 Next $750,000 Next $1,500,000 Next $2,000,000 Next $5,000,000 Next $15,000,000 Over $25,000,000 1.50% 1.00% 0.90% 0.80% 0.60% 0.50% 0.40% Negotiable Hilltop requires a total minimum fee of $6,250 and may elect, in its sole discretion, to waive any portion of this minimum. For portfolio values less than $417,000, clients may be able to obtain comparable services at a lower cost elsewhere. The client authorizes the qualified custodian to automatically deduct the fee and all other charges payable hereunder from the assets in the account when due with such payments to be reflected on the next account statement sent to the client. If insufficient cash is available to pay such fees, securities in an amount equal to the balance of unpaid fees will be liquidated to pay for the unpaid balance. Hilltop Wealth may modify the fee at any time upon 30 days’ written notice to the client. In the event the client has an ERISA-governed plan, fee modifications must be approved in writing by the client. Asset-based fees are always subject to the investment advisory agreement between the client and Hilltop Wealth. Such fees are payable monthly in arrears. The fees will be prorated if the investment advisory relationship commences otherwise than at the beginning of a calendar month. Adjustments for significant contributions to a client’s portfolio (10% of portfolio value) are prorated for the month in which the change occurs; no adjustments will be made for withdrawals. Financial Planning Fees For clients with at least $500,000 in assets under management with Hilltop Wealth, the firm will provide a financial plan at no additional cost. Such planning will include the client’s financial position, retirement planning (although does not include more complex retirement strategies, stock options, etc.), tax planning (more complex strategies may be additional, protection planning, and basic estate planning (more complex strategies may be additional). Page 9 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 5: Fees and Compensation For clients with less than $500,000 in assets under management, Hilltop Wealth will negotiate with the client a fixed fee which will be based upon an estimate of hours at an hourly rate of $250 per hour. Such financial plan may include net worth, cash flow analysis, tax planning, retirement analysis, other goal planning and estate planning. Hilltop Wealth will negotiate with the client a fixed fee, which typically ranges from $1,200 to $20,000 per year depending upon the complexity of the planning and the needs of the client. Generally, financial planning fees above $10,000 are more focused toward high net worth individuals, corporations, pension and profit sharing plans, and other businesses. Hilltop Wealth will provide the prospective client with an estimate of the charges prior to finalizing the financial planning agreement. Clients will be billed monthly, quarterly, or annually in arrears as agreed upon with the firm. Clients seeking to terminate this service must do so in writing. B. Client Payment of Fees Hilltop Wealth does not require the prepayment of its fees. Hilltop Wealth’s fees will either be paid directly by the client or disbursed to Hilltop Wealth by the qualified custodian of the client’s investment accounts, subject to prior written consent of the client. The custodian will deliver directly to the client an account statement, at least quarterly, showing all investment and transaction activity for the period, including fee disbursements from the account. A client investment advisory agreement may be canceled at any time by the client, or by Hilltop Wealth with 30 days’ prior written notice to the client. Upon termination of any account, any earned, unpaid fees will be due and payable. The client has the right to terminate an agreement without penalty within five business days after entering into the agreement. Hilltop Wealth requires clients to authorize the direct debit of fees from their accounts. Exceptions may be granted subject to the firm’s consent for clients to be billed directly for our fees. For directly debited fees, the custodian’s periodic statements will show each fee deduction from the account. Clients may withdraw this authorization for direct billing of these fees at any time by notifying us or their custodian in writing. Hilltop Wealth will deduct advisory fees directly from the client’s account provided that (i) the client provides written authorization to the qualified custodian, and (ii) the qualified custodian sends the client a statement, at least quarterly, indicating all amounts disbursed from the account. The client is responsible for verifying the accuracy of the fee calculation, as the client’s custodian will not verify the calculation. C. Additional Client Fees Charged All fees paid for investment advisory services are separate and distinct from the fees and expenses charged by exchange-traded funds, mutual funds, private placement, broker-dealers, and custodians retained by clients. Such fees and expenses are described in each exchange- traded fund and mutual fund’s prospectus, each private placement’s confidential offering memoranda, and by any broker-dealer or custodian retained by the client. Clients are advised to Page 10 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 5: Fees and Compensation read these materials carefully before investing. If a mutual fund also imposes sales charges, a client may pay an initial or deferred sales charge as further described in the mutual fund’s prospectus. A client using Hilltop Wealth may be precluded from using certain mutual funds or separate account managers because they may not be offered by the client's custodian. Please refer to the Brokerage Practices section (Item 12) for additional information regarding the firm’s brokerage practices. D. External Compensation for the Sale of Securities to Clients Hilltop Wealth advisory professionals are compensated primarily through receipt of a percentage of the total advisory fee billed to the client. No sales professionals are primarily compensated through a salary and bonus structure. Hilltop Wealth may be paid sales, service or administrative fees for the sale of mutual funds or any other investment products, including insurance products, with respect to managed advisory assets. Investment adviser representatives, in their capacity as a Purshe Kaplan and Sterling registered representative, are prohibited from earning an advisory fee on the securities value transferred from an advisory client’s Purshe Kaplan and Sterling brokerage account unless commissions earned on such securities transactions occurred at least a 12–18 months prior to the transfer. Please see Item 10.C. for detailed information and conflicts of interest. E. Important Disclosure – Custodian Investment Programs Please be advised that certain of the firm’s investment adviser representatives are registered with a broker-dealer and/or the firm is a broker-dealer or affiliated with a broker-dealer. Under these arrangements, we can access certain investment programs offered through the broker- dealer that offer certain compensation and fee structures that create conflicts of interest of which clients need to be aware. As such, the investment adviser representative and/or the firm may have an economic incentive to recommend the purchase of 12b-1 or revenue share class mutual funds offered through the broker-dealer platform rather than from the investment adviser platform. Please note the following: Limitation on Mutual Fund Universe for Custodian Investment Programs: Please note that as a matter of policy we prohibit the receipt of revenue share fees from any mutual funds utilized for our advisory clients’ portfolios. There are certain programs in which we participate where a client’s investment options may be limited in certain of these programs to those mutual funds and/or mutual fund share classes that pay 12b-1 fees and other revenue sharing fee payments, and the client should be aware that the firm is not selecting from among all mutual funds available in the marketplace when recommending mutual funds to the client. Conflict Between Revenue Share Class (12b-1) and Non-Revenue Share Class Mutual Funds: Revenue share class/12b-1 fees are deducted from the net asset value of the mutual fund and generally, all things being equal, cause the fund to earn lower rates of return than those mutual funds that do not pay revenue sharing fees. The client is under no obligation to utilize such programs or mutual funds. Although many factors will influence the type of fund to be used, the client should discuss with their investment adviser representative whether a share class from a Page 11 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 5: Fees and Compensation comparable mutual fund with a more favorable return to investors is available that does not include the payment of any 12b-1 or revenue sharing fees given the client’s individual needs and priorities and anticipated transaction costs. In addition, the receipt of such fees can create conflicts of interest in instances (i) where our adviser representative is also licensed as a registered representative of a broker-dealer and receives a portion of 12b-1 and or revenue sharing fees as compensation – such compensation creates an incentive for the investment adviser representative to use programs which utilize funds that pay such additional compensation; and (ii) where the custodian receives the entirety of the 12b-1 and/or revenue sharing fees and takes the receipt of such fees into consideration in terms of benefits it may elect to provide to the firm, even though such benefits may or may not benefit some or all of the firm clients. Page 12 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 6: Performance-Based Fees and Side-by-Side Management Item 6: Performance-Based Fees and Side-by-Side Management Hilltop Wealth does not charge performance-based fees and therefore has no economic incentive to manage clients’ portfolios in any way other than what is in their best interests. Page 13 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 7: Types of Clients Item 7: Types of Clients Hilltop Wealth offers its investment services to various types of clients including high-net-worth individuals, trusts, corporations, partnerships, retirement plans, tax exempt, and other legal entities. Hilltop requires a total minimum fee of $6,250 and may elect, in its sole discretion, to waive any portion of this minimum. For portfolio values less than $417,000, clients may be able to obtain comparable services at a lower cost elsewhere. Page 14 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Investment Strategies Hilltop Wealth uses a variety of sources of data to conduct its economic, investment and market analysis, such as financial newspapers and magazines, economic and market research materials prepared by others, conference calls hosted by mutual funds, corporate rating services, annual reports, prospectuses, and company press releases. It is important to keep in mind that there is no specific approach to investing that guarantees success or positive returns; investing in securities involves risk of loss that clients should be prepared to bear. Hilltop Wealth and its investment adviser representatives are responsible for identifying and implementing the methods of analysis used in formulating investment recommendations to clients. The methods of analysis may include quantitative methods for optimizing client portfolios, computer-based risk/return analysis, technical analysis, and statistical and/or computer models utilizing long-term economic criteria. ▪ Optimization involves the use of mathematical algorithms to determine the appropriate mix of assets given the firm’s current capital market rate assessment and a particular client’s risk tolerance. ▪ Quantitative methods include analysis of historical data such as price and volume statistics, performance data, standard deviation and related risk metrics, how the security performs relative to the overall stock market, earnings data, price to earnings ratios, and related data. ▪ Technical analysis involves charting price and volume data as reported by the exchange where the security is traded to look for price trends. ▪ Computer models may be used to derive the future value of a security based on assumptions of various data categories such as earnings, cash flow, profit margins, sales, and a variety of other company specific metrics. In addition, Hilltop Wealth reviews research material prepared by others, as well as corporate filings, corporate rating services, and a variety of financial publications. Hilltop Wealth may employ outside vendors or utilize third-party software to assist in formulating investment recommendations to clients. Mutual Funds and Exchange-Traded Funds Hilltop Wealth may recommend no-load and load-waived mutual funds and individual securities (including fixed income instruments). A description of the criteria to be used in formulating an investment recommendation for mutual funds, ETFs, and individual securities (including fixed-income securities), is set forth below. Hilltop Wealth has formed relationships with third-party vendors that ▪ provide a technological platform for separate account management ▪ prepare performance reports Page 15 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ▪ perform or distribute research of individual securities ▪ perform billing and certain other administrative tasks Hilltop Wealth may utilize additional independent third parties to assist it in recommending and monitoring individual securities and mutual funds to clients as appropriate under the circumstances. Hilltop Wealth reviews certain quantitative and qualitative criteria related to mutual funds and to formulate investment recommendations to its clients. Quantitative criteria may include ▪ the performance history of a mutual fund evaluated against that of its peers and other benchmarks ▪ an analysis of risk-adjusted returns ▪ an analysis of the fund’s contribution to the investment return, standard deviation of returns over specific time periods, sector and style analysis ▪ the fund’s fee structure ▪ the relevant portfolio manager’s tenure Qualitative criteria used in selecting/recommending mutual funds include the investment objectives and/or management style and philosophy of a mutual fund, a mutual fund’s consistency of investment style, and employee turnover and efficiency and capacity. Quantitative and qualitative criteria related to mutual funds are reviewed by Hilltop Wealth on a quarterly basis or such other interval as appropriate under the circumstances. In addition, mutual funds are reviewed to determine the extent to which their investments reflect efforts to time the market, or evidence style drift such that their portfolios no longer accurately reflect the particular asset category attributed to the mutual fund by Hilltop Wealth (both of which are negative factors in implementing an asset allocation structure). Hilltop Wealth may negotiate reduced account minimum balances and reduced fees under various circumstances (e.g., for clients with minimum level of assets committed for specific periods of time, etc.). There can be no assurance that clients will receive any reduced account minimum balances or fees, or that all clients, even if apparently similarly situated, will receive any reduced account minimum balances or fees available to some other clients. Also, account minimum balances and fees may significantly differ between clients. Each client’s individual needs and circumstances will determine portfolio weighting, which can have an impact on fees given the funds utilized. Hilltop Wealth will endeavor to obtain equal treatment for its clients with funds, but cannot assure equal treatment. Hilltop Wealth will regularly review the activities of mutual funds utilized for the client. Clients that invest in mutual funds should first review and understand the disclosure documents of those mutual funds, which contain information relevant to such retention or investment, including information on the methodology used to analyze securities, investment strategies, fees and conflicts of interest. Page 16 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Material Risks of Investment Instruments Hilltop Wealth may invest in open-end mutual funds and exchange-traded funds for the vast majority of its clients. In addition, for certain clients, Hilltop Wealth may effect transactions in the following types of securities: ▪ Equity securities ▪ Mutual fund securities ▪ Exchange-traded funds ▪ Fixed income securities ▪ Corporate debt securities, commercial paper, and certificates of deposit ▪ Municipal securities ▪ Corporate debt obligations ▪ Variable annuities ▪ Private placements Equity Securities Investing in individual companies involves inherent risk. The major risks relate to the company’s capitalization, quality of the company’s management, quality and cost of the company’s services, the company’s ability to manage costs, efficiencies in the manufacturing or service delivery process, management of litigation risk, and the company’s ability to create shareholder value (i.e., increase the value of the company’s stock price). Foreign securities, in addition to the general risks of equity securities, have geopolitical risk, financial transparency risk, currency risk, regulatory risk and liquidity risk. Mutual Fund Securities Investing in mutual funds carries inherent risk. The major risks of investing in a mutual fund include the quality and experience of the portfolio management team and its ability to create fund value by investing in securities that have positive growth, the amount of individual company diversification, the type and amount of industry diversification, and the type and amount of sector diversification within specific industries. In addition, mutual funds tend to be tax inefficient and therefore investors may pay capital gains taxes on fund investments while not having yet sold the fund. Exchange-Traded Funds (“ETFs”) ETFs are investment companies whose shares are bought and sold on a securities exchange. An ETF holds a portfolio of securities designed to track a particular market segment or index. Some examples of ETFs are SPDRs®, streetTRACKS®, DIAMONDSSM, NASDAQ 100 Index Tracking StockSM (“QQQs SM”) iShares® and VIPERs®. The funds could purchase an ETF to gain exposure to a portion of the U.S. or foreign market. The funds, as a shareholder of another investment company, will bear their pro-rata portion of the other investment company’s advisory fee and other expenses, in addition to their own expenses. Page 17 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Investing in ETFs involves risk. Specifically, ETFs, depending on the underlying portfolio and its size, can have wide price (bid and ask) spreads, thus diluting or negating any upward price movement of the ETF or enhancing any downward price movement. Also, ETFs require more frequent portfolio reporting by regulators and are thereby more susceptible to actions by hedge funds that could have a negative impact on the price of the ETF. Certain ETFs may employ leverage, which creates additional volatility and price risk depending on the amount of leverage utilized, the collateral and the liquidity of the supporting collateral. Further, the use of leverage (i.e., employing the use of margin) generally results in additional interest costs to the ETF. Certain ETFs are highly leveraged and therefore have additional volatility and liquidity risk. Volatility and liquidity can severely and negatively impact the price of the ETF’s underlying portfolio securities, thereby causing significant price fluctuations of the ETF. Fixed Income Securities Fixed income securities carry additional risks than those of equity securities described above. These risks include the company’s ability to retire its debt at maturity, the current interest rate environment, the coupon interest rate promised to bondholders, legal constraints, jurisdictional risk (U.S or foreign) and currency risk. If bonds have maturities of ten years or greater, they will likely have greater price swings when interest rates move up or down. The shorter the maturity the less volatile the price swings. Foreign bonds have liquidity and currency risk. Corporate Debt, Commercial Paper and Certificates of Deposit Fixed income securities carry additional risks than those of equity securities described above. These risks include the company’s ability to retire its debt at maturity, the current interest rate environment, the coupon interest rate promised to bondholders, legal constraints, jurisdictional risk (U.S or foreign) and currency risk. If bonds have maturities of ten years or greater, they will likely have greater price swings when interest rates move up or down. The shorter the maturity the less volatile the price swings. Foreign bonds also have liquidity and currency risk. Commercial paper and certificates of deposit are generally considered safe instruments, although they are subject to the level of general interest rates, the credit quality of the issuing bank and the length of maturity. With respect to certificates of deposit, depending on the length of maturity there can be prepayment penalties if the client needs to convert the certificate of deposit to cash prior to maturity. Municipal Securities Municipal securities carry additional risks than those of corporate and bank-sponsored debt securities described above. These risks include the municipality’s ability to raise additional tax revenue or other revenue (in the event the bonds are revenue bonds) to pay interest on its debt and to retire its debt at maturity. Municipal bonds are generally tax free at the federal level, but may be taxable in individual states other than the state in which both the investor and municipal issuer is domiciled. Page 18 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Corporate Debt Obligations Corporate debt obligations include corporate bonds, debentures, notes, commercial paper and other similar corporate debt instruments. Companies use these instruments to borrow money from investors. The issuer pays the investor a fixed or variable rate of interest and must repay the amount borrowed at maturity. Commercial paper (short-term unsecured promissory notes) is issued by companies to finance their current obligations and normally has a maturity of less than nine months. In addition, the firm may also invest in corporate debt securities registered and sold in the United States by foreign issuers (Yankee bonds) and those sold outside the U.S. by foreign or U.S. issuers (Eurobonds). Variable Annuities Variable Annuities are long-term financial products designed for retirement purposes. In essence, annuities are contractual agreements in which payment(s) are made to an insurance company, which agrees to pay out an income or a lump sum amount at a later date. There are contract limitations and fees and charges associated with annuities, administrative fees, and charges for optional benefits. They also may carry early withdrawal penalties and surrender charges, and carry additional risks such as the insurance carrier's ability to pay claims. Moreover, variable annuities carry investment risk similar to mutual funds. Investors should carefully review the terms of the variable annuity contract before investing. Private Placements Private placements carry significant risk in that companies using the private placement market conduct securities offerings that are exempt from registration under the federal securities laws, which means that investors do not have access to public information and such investors are not provided with the same amount of information that they would receive if the securities offering was a public offering. Moreover, many companies using private placements do so to raise equity capital in the start-up phase of their business, or require additional capital to complete another phase in their growth objective. In addition, the securities issued in connection with private placements are restricted securities, which means that they are not traded on a secondary market, such as a stock exchange, and they are thus illiquid and cannot be readily converted to cash. B. Investment Strategy and Method of Analysis Material Risks Our investment strategy is custom-tailored to the client’s goals, investment objectives, risk tolerance, and personal and financial circumstances. Margin Leverage Although Hilltop Wealth, as a general business practice, does not utilize leverage, there may be instances in which exchange-traded funds, other separate account managers and, in very limited circumstances, Hilltop Wealth will utilize leverage. In this regard please review the following: The use of margin leverage enhances the overall risk of investment gain and loss to the client’s investment portfolio. For example, investors are able to control $2 of a security for $1. So if the Page 19 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss price of a security rises by $1, the investor earns a 100% return on their investment. Conversely, if the security declines by $.50, then the investor loses 50% of their investment. The use of margin leverage entails borrowing, which results in additional interest costs to the investor. Broker-dealers who carry customer accounts require a minimum equity requirement when clients utilize margin leverage. The minimum equity requirement is stated as a percentage of the value of the underlying collateral security with an absolute minimum dollar requirement. For example, if the price of a security declines in value to the point where the excess equity used to satisfy the minimum requirement dissipates, the broker-dealer will require the client to deposit additional collateral to the account in the form of cash or marketable securities. A deposit of securities to the account will require a larger deposit, as the security being deposited is included in the computation of the minimum equity requirement. In addition, when leverage is utilized and the client needs to withdraw cash, the client must sell a disproportionate amount of collateral securities to release enough cash to satisfy the withdrawal amount based upon similar reasoning as cited above. Regulations concerning the use of margin leverage are established by the Federal Reserve Board and vary if the client’s account is held at a broker-dealer versus a bank custodian. Broker-dealers and bank custodians may apply more stringent rules as they deem necessary. Short-Term Trading Although Hilltop Wealth, as a general business practice, does not utilize short-term trading, there may be instances in which short-term trading may be necessary or an appropriate strategy. In this regard, please read the following: There is an inherent risk for clients who trade frequently in that high-frequency trading creates substantial transaction costs that in the aggregate could negatively impact account performance. Short Selling Hilltop Wealth generally does not engage in short selling but reserves the right to do so in the exercise of its sole judgment. Short selling involves the sale of a security that is borrowed rather than owned. When a short sale is effected, the investor is expecting the price of the security to decline in value so that a purchase or closeout of the short sale can be effected at a significantly lower price. The primary risks of effecting short sales is the availability to borrow the stock, the unlimited potential for loss, and the requirement to fund any difference between the short credit balance and the market value of the security. Technical Trading Models Technical trading models are mathematically driven based upon historical data and trends of domestic and foreign market trading activity, including various industry and sector trading statistics within such markets. Technical trading models, through mathematical algorithms, attempt to identify when markets are likely to increase or decrease and identify appropriate Page 20 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss entry and exit points. The primary risk of technical trading models is that historical trends and past performance cannot predict future trends, and there is no assurance that the mathematical algorithms employed are designed properly, updated with new data, and can accurately predict future market, industry, and sector performance. Option Strategies Various option strategies give the holder the right to acquire or sell underlying securities at the contract strike price up until expiration of the option. Each contract is worth 100 shares of the underlying security. Options entail greater risk but allow an investor to have market exposure to a particular security or group of securities without the capital commitment required to purchase the underlying security or groups of securities. In addition, options allow investors to hedge security positions held in the portfolio. For detailed information on the use of options and option strategies, please contact the Options Clearing Corporation for the current Options Risk Disclosure Statement. Hilltop Wealth as part of its investment strategy may employ the following option strategies: ▪ Covered call writing ▪ Long call options purchases ▪ Long put options purchases Covered Call Writing Covered call writing is the sale of in-, at-, or out-of-the-money call option against a long security position held in the client portfolio. This type of transaction is used to generate income. It also serves to create downside protection in the event the security position declines in value. Income is received from the proceeds of the option sale. Such income may be reduced to the extent it is necessary to buy back the option position prior to its expiration. This strategy may involve a degree of trading velocity, transaction costs and significant losses if the underlying security has volatile price movement. Covered call strategies are generally suited for companies with little price volatility. Long Call Option Purchases Long call option purchases allow the option holder to be exposed to the general market characteristics of a security without the outlay of capital necessary to own the security. Options are wasting assets and expire (usually within nine months of issuance), and as a result can expose the investor to significant loss. Long Put Option Purchases Long put option purchases allow the option holder to sell or “put” the underlying security at the contract strike price at a future date. If the price of the underlying security declines in value, the value of the long put option increases. In this way long puts are often used to hedge a long stock position. Options are wasting assets and expire (usually within nine months of issuance), and as a result can expose the investor to significant loss. Page 21 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss C. Security-Specific Material Risks There is an inherent risk for clients who have their investment portfolios heavily weighted in one security, one industry or industry sector, one geographic location, one investment manager, one type of investment instrument (equities versus fixed income). Clients who have diversified portfolios, as a general rule, incur less volatility and therefore less fluctuation in portfolio value than those who have concentrated holdings. Concentrated holdings may offer the potential for higher gain, but also offer the potential for significant loss. Page 22 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 9: Disciplinary Information Item 9: Disciplinary Information A. Criminal or Civil Actions There is nothing to report on this item. B. Administrative Enforcement Proceedings There is nothing to report on this item. C. Self-Regulatory Organization Enforcement Proceedings There is nothing to report on this item. Page 23 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 10: Other Financial Industry Activities and Affiliations Item 10: Other Financial Industry Activities and Affiliations A. Broker-Dealer or Representative Registration Neither Hilltop Wealth nor its affiliates are registered broker-dealers and do not have an application to register pending. Certain managers, members, and registered personnel of Hilltop Wealth are associated persons of Purshe Kaplan Sterling Investments. Please see below for conflict disclosure. B. Futures or Commodity Registration Neither Hilltop Wealth nor its affiliates are registered as a commodity firm, futures commission merchant, commodity pool operator or commodity trading advisor and do not have an application to register pending. C. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Broker-Dealer Registration Managers, members, and registered personnel of Hilltop Wealth are associated persons of Purshe Kaplan Sterling Investments (“PKS”), a FINRA-registered broker-dealer and member of SIPC. As a result, such professionals, in their capacity as registered representatives of PKS, are subject to the oversight of PKS and the Financial Industry Regulatory Authority, Inc. (“FINRA”). As such, clients of Hilltop Wealth should understand that their personal and account information is available to FINRA and PKS personnel in the fulfillment of their oversight obligations and duties. Hilltop Wealth professionals who effect transactions for advisory clients may receive transaction or commission compensation from PKS. The recommendation of securities transactions for commission creates a conflict of interest in that Hilltop Wealth is economically incented to effect securities transactions for clients. Although Hilltop Wealth strives to put its clients’ interests first, such recommendations may be viewed as being in the best interests of Hilltop Wealth rather than in the client’s best interest. Hilltop Wealth advisory clients are not compelled to effect securities transactions through PKS. Insurance Sales Certain managers, members, and registered employees of Hilltop Wealth are licensed insurance agents. With respect to the provision of financial planning services, Hilltop Wealth professionals may recommend insurance products offered by such carriers for whom they function as an agent and receive a commission for doing so. Please be advised there is a conflict of interest in that there is an economic incentive to recommend insurance and other investment products of such carriers. Please also be advised that Hilltop Wealth strives to put its clients’ interests first and foremost. Other than for insurance products that require a securities license, such as variable insurance products, clients may utilize any insurance carrier or insurance agency they Page 24 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 10: Other Financial Industry Activities and Affiliations desire. For products requiring a securities and insurance license, clients may be limited to those insurance carriers that have a selling agreement with Hilltop Wealth’s employing broker-dealer. Hilltop Tax Solutions, LLC Erik Brenner is an owner of Hilltop Tax Solutions, LLC (“Hilltop Tax”), a limited liability company and affiliate of Hilltop Wealth. Hilltop Tax provides tax and bookkeeping services. Clients of Hilltop Wealth are advised there is a conflict of interest in that there is an economic incentive to recommend Hilltop Tax. Hilltop Wealth professionals strive to put their clients’ interests first and foremost, and clients may utilize tax and accounting services of their choosing. Hilltop Kids Hilltop Wealth and Hilltop Kids are under common control. Hilltop Kids is a 501(c)(3) status entity with the IRS. Hilltop Kids serves to collect donations to be used for at-risk youth programs. Hilltop Wealth may have an economic incentive to favor clients who donate to Hilltop Kids. However, Hilltop Wealth maintains policies, procedures, and controls to routinely monitor these conflicts to help ensure that clients are treated fairly and equitably. Pinnacle Renewable Solutions Erik Brenner is an owner of Pinnacle Renewable Solutions, which provides clients with a way to utilize tax credits by setting up their own solar company. Clients of Hilltop Wealth are advised there is a conflict of interest in that there is an economic incentive to recommend Pinnacle Renewable Solutions. Book Authorship Erik Brenner is the author of The Personal CFO Revolution, which is available for purchase on Amazon. Clients of Hilltop Wealth are advised there is a conflict of interest in that there is an economic incentive to recommend Mr. Brenner’s book. D. Recommendation or Selection of Other Investment Advisors and Conflicts of Interest Hilltop Wealth does not recommend separate account managers or other investment products in which it receives any form of referral or solicitor compensation from the separate account manager or client. Page 25 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Description In accordance with the Advisers Act, Hilltop Wealth has adopted policies and procedures designed to detect and prevent insider trading. In addition, Hilltop Wealth has adopted a Code of Ethics (the “Code”). Among other things, the Code includes written procedures governing the conduct of Hilltop Wealth's advisory and access persons. The Code also imposes certain reporting obligations on persons subject to the Code. The Code and applicable securities transactions are monitored by the chief compliance officer of Hilltop Wealth. Hilltop Wealth will send clients a copy of its Code of Ethics upon written request. Hilltop Wealth has policies and procedures in place to ensure that the interests of its clients are given preference over those of Hilltop Wealth, its affiliates and its employees. For example, there are policies in place to prevent the misappropriation of material non-public information, and such other policies and procedures reasonably designed to comply with federal and state securities laws. B. Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest Hilltop Wealth does not engage in principal trading (i.e., the practice of selling stock to advisory clients from a firm’s inventory or buying stocks from advisory clients into a firm’s inventory). In addition, Hilltop Wealth does not recommend any securities to advisory clients in which it has some proprietary or ownership interest. C. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Hilltop Wealth, its affiliates, employees and their families, trusts, estates, charitable organizations and retirement plans established by it may purchase the same securities as are purchased for clients in accordance with its Code of Ethics policies and procedures. The personal securities transactions by advisory representatives and employees may raise potential conflicts of interest when they trade in a security that is: ▪ owned by the client, or ▪ considered for purchase or sale for the client. Such conflict generally refers to the practice of front-running (trading ahead of the client), which Hilltop Wealth specifically prohibits. Hilltop Wealth has adopted policies and procedures that are intended to address these conflicts of interest. These policies and procedures: ▪ require our advisory representatives and employees to act in the client’s best interest ▪ prohibit fraudulent conduct in connection with the trading of securities in a client account Page 26 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ▪ prohibit employees from personally benefitting by causing a client to act, or fail to act in making investment decisions ▪ prohibit the firm or its employees from profiting or causing others to profit on knowledge of completed or contemplated client transactions ▪ allocate investment opportunities in a fair and equitable manner ▪ provide for the review of transactions to discover and correct any trades that result in an advisory representative or employee benefitting at the expense of a client. Advisory representatives and employees must follow Hilltop Wealth’s procedures when purchasing or selling the same securities purchased or sold for the client. D. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest Hilltop Wealth, its affiliates, employees and their families, trusts, estates, charitable organizations, and retirement plans established by it may effect securities transactions for their own accounts that differ from those recommended or effected for other Hilltop Wealth clients. Hilltop Wealth will make a reasonable attempt to trade securities in client accounts at or prior to trading the securities in its affiliate, corporate, employee or employee-related accounts. Trades executed the same day will likely be subject to an average pricing calculation. It is the policy of Hilltop Wealth to place the clients’ interests above those of Hilltop Wealth and its employees. Page 27 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 12: Brokerage Practices Item 12: Brokerage Practices A. Factors Used to Select Broker-Dealers for Client Transactions Custodian Recommendations Hilltop Wealth may recommend that clients establish brokerage accounts with Charles Schwab & Co., Inc. (“custodian), a FINRA registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. Although Hilltop Wealth may recommend that clients establish accounts at the custodian, it is the client’s decision to custody assets with the custodian. Hilltop Wealth is independently owned and operated and not affiliated with custodian. For Hilltop Wealth-managed advisory accounts, the custodian generally does not charge separately for custody services but is compensated by account holders through commissions and other transaction-related or asset-based fees for securities trades that are executed through the custodian or that settle into custodian accounts. Hilltop Wealth considers the financial strength, reputation, operational efficiency, cost, execution capability, level of customer service, and related factors in recommending broker-dealers or custodians to advisory clients. In certain instances and subject to approval by Hilltop Wealth, Hilltop Wealth will recommend to clients certain other broker-dealers and/or custodians based on the needs of the individual client, and taking into consideration the nature of the services required, the experience of the broker-dealer or custodian, the cost and quality of the services, and the reputation of the broker-dealer or custodian. The final determination to engage a broker-dealer or custodian recommended by Hilltop Wealth will be made by and in the sole discretion of the client. The client recognizes that broker-dealers and/or custodians have different cost and fee structures and trade execution capabilities. As a result, there may be disparities with respect to the cost of services and/or the transaction prices for securities transactions executed on behalf of the client. Clients are responsible for assessing the commissions and other costs charged by broker-dealers and/or custodians. How We Select Brokers/Custodians to Recommend Hilltop Wealth seeks to recommend a custodian/broker who will hold client assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others, the following: ▪ combination of transaction execution services along with asset custody services (generally without a separate fee for custody) ▪ capability to execute, clear, and settle trades (buy and sell securities for client accounts) ▪ capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) ▪ breadth of investment products made available (stocks, bonds, mutual funds, exchange- traded funds (ETFs), etc.) Page 28 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 12: Brokerage Practices ▪ availability of investment research and tools that assist us in making investment decisions ▪ quality of services ▪ competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate them ▪ reputation, financial strength, and stability of the provider ▪ their prior service to us and our other clients ▪ availability of other products and services that benefit us, as discussed below Soft Dollar Arrangements The does not utilize soft dollar arrangements. The firm does not direct brokerage transactions to executing brokers for research and brokerage services. Institutional Trading and Custody Services The custodian provides Hilltop Wealth with access to its institutional trading and custody services, which are typically not available to the custodian’s retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a certain minimum amount of the advisor’s clients’ assets are maintained in accounts at a particular custodian. The custodian’s brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Other Products and Services Custodian also makes available to Hilltop Wealth other products and services that benefit Hilltop Wealth but may not directly benefit its clients’ accounts. Many of these products and services may be used to service all or some substantial number of Hilltop Wealth's accounts, including accounts not maintained at custodian. The custodian may also make available to Hilltop Wealth software and other technology that ▪ provide access to client account data (such as trade confirmations and account statements) ▪ facilitate trade execution and allocate aggregated trade orders for multiple client accounts ▪ provide research, pricing and other market data ▪ facilitate payment of Hilltop Wealth’s fees from its clients’ accounts ▪ assist with back-office functions, recordkeeping and client reporting The custodian may also offer other services intended to help Hilltop Wealth manage and further develop its business enterprise. These services may include ▪ compliance, legal and business consulting ▪ publications and conferences on practice management and business succession Page 29 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 12: Brokerage Practices ▪ access to employee benefits providers, human capital consultants and insurance providers The custodian may also provide other benefits such as educational events or occasional business entertainment of Hilltop Wealth personnel. In evaluating whether to recommend that clients custody their assets at the custodian, Hilltop Wealth may take into account the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors it considers, and not solely the nature, cost or quality of custody and brokerage services provided by the custodian, which creates a conflict of interest. Independent Third Parties The custodian may make available, arrange, and/or pay third-party vendors for the types of services rendered to Hilltop Wealth. The custodian may discount or waive fees it would otherwise charge for some of these services or all or a part of the fees of a third party providing these services to Hilltop Wealth. Additional Compensation Received from Custodians Hilltop Wealth may participate in institutional customer programs sponsored by broker- dealers or custodians. Hilltop Wealth may recommend these broker-dealers or custodians to clients for custody and brokerage services. There is no direct link between Hilltop Wealth’s participation in such programs and the investment advice it gives to its clients, although Hilltop Wealth receives economic benefits through its participation in the programs that are typically not available to retail investors. These benefits may include the following products and services (provided without cost or at a discount): ▪ Receipt of duplicate client statements and confirmations ▪ Research-related products and tools ▪ Consulting services ▪ Access to a trading desk serving Hilltop Wealth participants ▪ Access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts) ▪ The ability to have advisory fees deducted directly from client accounts ▪ Access to an electronic communications network for client order entry and account information ▪ Access to mutual funds with no transaction fees and to certain institutional money managers ▪ Discounts on compliance, marketing, research, technology, and practice management products or services provided to Hilltop Wealth by third-party vendors The custodian may also pay for business consulting and professional services received by Hilltop Wealth’s related persons, and may pay or reimburse expenses (including client transition expenses, travel, lodging, meals and entertainment expenses for Hilltop Wealth’s personnel to attend conferences). Some of the products and services made available by such custodian through its institutional customer programs may benefit Hilltop Wealth but may not Page 30 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 12: Brokerage Practices benefit its client accounts. These products or services may assist Hilltop Wealth in managing and administering client accounts, including accounts not maintained at the custodian as applicable. Other services made available through the programs are intended to help Hilltop Wealth manage and further develop its business enterprise. The benefits received by Hilltop Wealth or its personnel through participation in these programs do not depend on the amount of brokerage transactions directed to the broker-dealer. Hilltop Wealth also participates in similar institutional advisor programs offered by other independent broker-dealers or trust companies, and its continued participation may require Hilltop Wealth to maintain a predetermined level of assets at such firms. In connection with its participation in such programs, Hilltop Wealth will typically receive benefits similar to those listed above, including research, payments for business consulting and professional services received by Hilltop Wealth’s related persons, and reimbursement of expenses (including travel, lodging, meals and entertainment expenses for Hilltop Wealth’s personnel to attend conferences sponsored by the broker-dealer or trust company). As part of its fiduciary duties to clients, Hilltop Wealth endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by Hilltop Wealth or its related persons in and of itself creates a conflict of interest and indirectly influences Hilltop Wealth’s recommendation of broker-dealers for custody and brokerage services. The Firm’s Interest in Custodian’s Services The availability of these services from the custodian benefits the firm because the firm does not have to produce or purchase them. The firm does not have to pay for the custodian’s services so long as a certain minimum of client assets is kept in accounts at the custodian. Custodian’s services give the firm an incentive to recommend that clients maintain their accounts with the custodian based on the firm’s interest in receiving the custodian’s services that benefit the firm’s business rather than based on the client’s interest in receiving the best value in custody services and the most favorable execution of client transactions. This is a conflict of interest. The firm believes, however, that the selection of the custodian as custodian and broker is in the best interest of clients. It is primarily supported by the scope, quality, and price of the custodian’s services and not the custodian’s services that benefit only the firm. Brokerage for Client Referrals Hilltop Wealth does not engage in the practice of directing brokerage commissions in exchange for the referral of advisory clients. Directed Brokerage Hilltop Wealth Recommendations Hilltop Wealth typically recommends Schwab as custodian for clients’ funds and securities and to execute securities transactions on its clients’ behalf. Page 31 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 12: Brokerage Practices Client-Directed Brokerage Occasionally, clients may direct Hilltop Wealth to use a particular broker-dealer to execute portfolio transactions for their account or request that certain types of securities not be purchased for their account. Clients who designate the use of a particular broker-dealer should be aware that they will lose any possible advantage Hilltop Wealth derives from aggregating transactions. Such client trades are typically effected after the trades of clients who have not directed the use of a particular broker-dealer. Hilltop Wealth loses the ability to aggregate trades with other Hilltop Wealth advisory clients, potentially subjecting the client to inferior trade execution prices as well as higher commissions. B. Aggregating Securities Transactions for Client Accounts Best Execution Hilltop Wealth, pursuant to the terms of its investment advisory agreement with clients, has discretionary authority to determine which securities are to be bought and sold, and the amount of such securities. Hilltop Wealth recognizes that the analysis of execution quality involves a number of factors, both qualitative and quantitative. Hilltop Wealth will follow a process in an attempt to ensure that it is seeking to obtain the most favorable execution under the prevailing circumstances when placing client orders. These factors include but are not limited to the following: ▪ The financial strength, reputation and stability of the broker ▪ The efficiency with which the transaction is effected ▪ The ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any) ▪ The availability of the broker to stand ready to effect transactions of varying degrees of difficulty in the future ▪ The efficiency of error resolution, clearance and settlement ▪ Block trading and positioning capabilities ▪ Performance measurement ▪ Online access to computerized data regarding customer accounts ▪ Availability, comprehensiveness, and frequency of brokerage and research services ▪ Commission rates ▪ The economic benefit to the client ▪ Related matters involved in the receipt of brokerage services Consistent with its fiduciary responsibilities, Hilltop Wealth seeks to ensure that clients receive best execution with respect to clients’ transactions by blocking client trades to reduce commissions and transaction costs. To the best of Hilltop Wealth’s knowledge, these custodians provide high-quality execution, and Hilltop Wealth’s clients do not pay higher transaction costs in return for such execution. Page 32 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 12: Brokerage Practices Commission rates and securities transaction fees charged to effect such transactions are established by the client’s independent custodian and/or broker-dealer. Based upon its own knowledge of the securities industry, Hilltop Wealth believes that such commission rates are competitive within the securities industry. Lower commissions or better execution may be able to be achieved elsewhere. Security Allocation Since Hilltop Wealth may be managing accounts with similar investment objectives, Hilltop Wealth may aggregate orders for securities for such accounts. In such event, allocation of the securities so purchased or sold, as well as expenses incurred in the transaction, is made by Hilltop Wealth in the manner it considers to be the most equitable and consistent with its fiduciary obligations to such accounts. Hilltop Wealth’s allocation procedures seek to allocate investment opportunities among clients in the fairest possible way, taking into account the clients’ best interests. Hilltop Wealth will follow procedures to ensure that allocations do not involve a practice of favoring or discriminating against any client or group of clients. Account performance is never a factor in trade allocations. Hilltop Wealth’s advice to certain clients and entities and the action of Hilltop Wealth for those and other clients are frequently premised not only on the merits of a particular investment, but also on the suitability of that investment for the particular client in light of his or her applicable investment objective, guidelines and circumstances. Thus, any action of Hilltop Wealth with respect to a particular investment may, for a particular client, differ or be opposed to the recommendation, advice, or actions of Hilltop Wealth to or on behalf of other clients. Order Aggregation Orders for the same security entered on behalf of more than one client will generally be aggregated (i.e., blocked or bunched) subject to the aggregation being in the best interests of all participating clients. Subsequent orders for the same security entered during the same trading day may be aggregated with any previously unfilled orders. Subsequent orders may also be aggregated with filled orders if the market price for the security has not materially changed and the aggregation does not cause any unintended duration exposure. All clients participating in each aggregated order will receive the average price and, subject to minimum ticket charges and possible step outs, pay a pro rata portion of commissions. To minimize performance dispersion, “strategy” trades should be aggregated and average priced. However, when a trade is to be executed for an individual account and the trade is not in the best interests of other accounts, then the trade will only be performed for that account. This is true even if Hilltop Wealth believes that a larger size block trade would lead to best overall price for the security being transacted. Allocation of Trades All allocations will be made prior to the close of business on the trade date. In the event an order is “partially filled,” the allocation will be made in the best interests of all the clients in the Page 33 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 12: Brokerage Practices order, taking into account all relevant factors including, but not limited to, the size of each client’s allocation, clients’ liquidity needs and previous allocations. In most cases, accounts will get a pro forma allocation based on the initial allocation. This policy also applies if an order is “over-filled.” Hilltop Wealth acts in accordance with its duty to seek best price and execution and will not continue any arrangements if Hilltop Wealth determines that such arrangements are no longer in the best interest of its clients. Page 34 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 13: Review of Accounts Item 13: Review of Accounts A. Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Accounts are reviewed by Hilltop Wealth’s Manager. The frequency of reviews is determined based on the client’s investment objectives, but reviews are conducted no less frequently than semi-annually. More frequent reviews may also be triggered by a change in the client’s investment objectives, tax considerations, large deposits or withdrawals, large purchases or sales, loss of confidence in corporate management, or changes in macro-economic climate. Financial planning clients receive their financial plans and recommendations at the time service is completed. There are no post-plan reviews unless engaged to do so by the client. B. Review of Client Accounts on Non-Periodic Basis Hilltop Wealth may perform ad hoc reviews on an as-needed basis if there have been material changes in the client’s investment objectives or risk tolerance, or a material change in how Hilltop Wealth formulates investment advice. C. Content of Client-Provided Reports and Frequency The client’s independent custodian provides account statements directly to the client no less frequently than quarterly. The custodian’s statement is the official record of the client’s securities account and supersedes any statements or reports created on behalf of the client by Hilltop Wealth. Page 35 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 14: Client Referrals and Other Compensation Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Schwab Hilltop Wealth receives an economic benefit from Schwab in the form of the support products and services it makes available to us; please note that the availability of these products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. These products and services, how they benefit us, and the related conflicts of interest are described above under Item 12: Brokerage Practices. B. Advisory Firm Payments for Client Referrals Employee Compensation for Referrals Hilltop Wealth compensates its employees who attract additional managed assets to the firm. While this creates a conflict of interest, the firm has a fiduciary duty to act in the best interest of clients as defined in the Code of Ethics, which is further discussed in Item 11 of this Brochure. Podcasts Hilltop Wealth has a contractual arrangement with Interview Valet for podcast interview marketing services. No client or potential client should assume that any information presented or made available on or through podcasts, radio, websites, banners, or social media should be construed as personalized financial planning or investment advice. Personalized financial planning and investment advice can only be rendered after engagement of Hilltop Wealth, execution of the required documentation, and receipt of required disclosures. Page 36 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 15: Custody Item 15: Custody Hilltop Wealth is considered to have custody of client assets for purposes of the Advisers Act for the following reasons: ▪ The client authorizes us to instruct their custodian to deduct our advisory fees directly from the client’s account. The custodian maintains actual custody of clients’ assets. ▪ Our authority to direct client requests, utilizing standing instructions, for wire transfer of funds for first-party money movement and third-party money movement (checks and/or journals, ACH, Fed-wires). The firm has elected to meet the SEC’s seven conditions to avoid the surprise custody exam, as outlined below: 1. The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. 4. The client has the ability to terminate or change the instruction to the client’s qualified custodian. 5. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. 6. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. 7. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Individual advisory clients will receive at least quarterly account statements directly from their custodian containing a description of all activity, cash balances, and portfolio holdings in their accounts. Clients are urged to compare the account balance(s) shown on their account statements to the quarter-end balance(s) on their custodian's monthly statement. The custodian’s statement is the official record of the account. Page 37 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 16: Investment Discretion Item 16: Investment Discretion Clients may grant a limited power of attorney to Hilltop Wealth with respect to trading activity in their accounts by signing the appropriate custodian limited power of attorney form. In those cases, Hilltop Wealth will exercise full discretion as to the nature and type of securities to be purchased and sold, and the amount of securities for such transactions. Investment limitations may be designated by the client as outlined in the investment advisory agreement. Page 38 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 17: Voting Client Securities Item 17: Voting Client Securities Hilltop Wealth does not take discretion with respect to voting proxies on behalf of its clients. Hilltop Wealth will endeavor to make recommendations to clients on voting proxies regarding shareholder vote, consent, election or similar actions solicited by, or with respect to, issuers of securities beneficially held as part of Hilltop Wealth supervised and/or managed assets. In no event will Hilltop Wealth take discretion with respect to voting proxies on behalf of its clients. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Except as required by applicable law, Hilltop Wealth will not be obligated to render advice or take any action on behalf of clients with respect to assets presently or formerly held in their accounts that become the subject of any legal proceedings, including bankruptcies. From time to time, securities held in the accounts of clients will be the subject of class action lawsuits. Hilltop Wealth has no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit. Hilltop Wealth also has no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, Hilltop Wealth has no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. Where Hilltop Wealth receives written or electronic notice of a class action lawsuit, settlement, or verdict affecting securities owned by a client, it will forward all notices, proof of claim forms, and other materials to the client. Electronic mail is acceptable where appropriate and where the client has authorized contact in this manner. Page 39 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure  Item 18: Financial Information Item 18: Financial Information A. Balance Sheet Hilltop Wealth does not require the prepayment of fees of $1200 or more, six months or more in advance, and as such is not required to file a balance sheet. B. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients Hilltop Wealth does not have any financial issues that would impair its ability to provide services to clients. C. Bankruptcy Petitions During the Past Ten Years There is nothing to report on this item. Page 40 Part 2A of Form ADV: Hilltop Partners, LLC, Brochure