Overview
- Total Firm Assets
- $100 million
- Average High-Net-Worth Client Portfolio Size
- $2.5 million
- Minimum Account Size
- $1,000,000
Fee Structure
Primary Fee Schedule (FIRM BROCHURE/ADV PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $250,000 | 1.75% |
| $250,001 | $450,000 | 1.50% |
| $450,001 | $800,000 | 1.35% |
| $800,001 | $1,000,000 | 1.25% |
| $1,000,001 | $2,000,000 | 1.00% |
| $2,000,001 | and above | 0.85% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $14,600 | 1.46% |
| $5 million | $50,100 | 1.00% |
| $10 million | $92,600 | 0.93% |
| $50 million | $432,600 | 0.87% |
| $100 million | $857,600 | 0.86% |
Clients
- High-Net-Worth Share of Firm Assets
- 84.55%
- Number of High-Net-Worth Clients
- 34
- Total Client Accounts
- 264
- Discretionary Accounts
- 199
- Non-Discretionary Accounts
- 65
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 159966
Primary Brochure: FIRM BROCHURE/ADV PART 2A (2026-06-29)
View Document Text
W E A L T H M A N A G E M E N T, L L C
FIRM BROCHURE
(ADV PART 2A)
June 25, 2026
Hilpan Moxie Wealth Management, LLC
13 Woodland Drive
Irvine, CA 92604
Phone: 949-559-1852 ■ Toll: 877-366-3553, ext. 1 ■ Fax: 949-209-2518 ■ Email: don.hilario@hilpanmoxie.com
This brochure provides information about the qualifications and business practices of Hilpan
Moxie Wealth Management, LLC. If you have any questions about the contents of this
brochure, please contact Don Douglas Hilario, CFP® at (949) 559-1852 or
don.hilario@hilpanmoxie.com. 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.
Hilpan Moxie Wealth Management, LLC is an SEC registered investment adviser. Registration
of an Investment Adviser does not imply any level of skill or training. The written
communications of an Adviser provide you with information about which you determine to hire
or retain an Adviser.
Additional information about Hilpan Moxie Wealth Management, LLC is available on the
SEC’s website www.adviserinfo.sec.gov. You can search this site by a unique identifying
number, known as a CRD number. The CRD number for the Firm is 159966.
2. MATERIAL CHANGES
Since the last ADV Part 2A, dated March 16, 2026, there has been the following material
update to this ADV Part 2A:
• The Firm submitted for registration with the Securities and Exchange Commission (“SEC”).
Hilpan Moxie Wealth Management, LLC
Page 2 ADV Part 2A
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 .................................................................................................... 5
Item 6. Performance-Based Fees and Side-By-Side Management............................................. 7
Item 7. Types of Clients ................................................................................................................. 7
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ...................................... 7
Item 9. Disciplinary Information .................................................................................................. 9
Item 10. Other Financial Industry Activities and Affiliations ................................................ 10
Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading......................................................................................................................................... 10
Item 12. Brokerage Practices ...................................................................................................... 12
Item 13. Review of Accounts ....................................................................................................... 13
Item 14. Client Referrals and Other Compensation ................................................................. 14
Item 15. Custody .......................................................................................................................... 14
Item 16. Investment Discretion ................................................................................................... 14
Item 17. Voting Client Securities ................................................................................................ 14
Item 18. Financial Information ................................................................................................... 14
Item 19. Requirements for State-Registered Advisers .............................................................. 15
Hilpan Moxie Wealth Management, LLC
Page 3 ADV Part 2A
4. ADVISORY BUSINESS
A. OWNERSHIP/ADVISORY HISTORY
Hilpan Moxie Wealth Management, LLC (“Hilpan Moxie”) is a California corporation. Hilpan
Moxie was originally registered as a California investment adviser under the name of Donald D.
Hilario on February 10, 2012. The firm changed to Hilpan Moxie Wealth Management, LLC in
November 2012. The firm is wholly owned by Donald D. Hilario CFP®. (Don Douglas Hilario,
CFP®). Additional information about Mr. Hilario can be found in Item 19.
B. ADVISORY SERVICES OFFERED
Hilpan Moxie provides clients with a financial plan and portfolio management services for one
fee. Prior to the Adviser-Client relationship, Hilpan Moxie may offer a complimentary general
consultation to discuss services available, to give a prospective client time to review services
desired, and to determine the possibility of a potential relationship. Investment advisory services
begin only after the client and Hilpan Moxie formalize the relationship with a properly executed
client Agreement.
After engaging Hilpan Moxie, the client will be asked to share in a data gathering and discovery
process in an effort to determine the client’s stated needs, goals, intentions, time horizons, risk
tolerance and investment objectives. With this information Hilpan Moxie will create a written
financial plan for the client. The written financial plan will be tailored to the client’s specific
situation, and it may cover a variety of topics such as financial and cash management, risk
management, estate planning, tax issues, retirement planning, educational funding, goal setting,
or other needs as identified by the client and Hilpan Moxie. At the conclusion of the financial
planning portion of the investment advisory service the client will receive a written financial
plan.
After receiving the financial plan, Hilpan Moxie and the client will create a customized portfolio
that Hilpan Moxie will manage for the client. Similar to the unique written financial plan, Hilpan
Moxie will work with the client to formulate an individualized portfolio based upon his/her
objectives, time frame, risk parameters and other investment considerations. The portfolio may
contain stocks, bonds, mutual funds, exchange traded funds or other investment products that are
agreed upon by the client. Hilpan Moxie will actively manage and review all client accounts,
where accounts are monitored on a monthly basis.
Typically, financial planning and portfolio management are offered together for one fee.
However, Hilpan Moxie offers each as a standalone service (i.e., clients may request financial
planning without portfolio management services or clients may request portfolio management
services without the financial planning component).
Hilpan Moxie Wealth Management, LLC
Page 4 ADV Part 2A
C. TAILORED SERVICES
Advisory services are individualized to each client. However, Hilpan Moxie generally does not
allow clients to place restrictions on the types of securities held in their accounts, though Don
Hilario, as Principal of Hilpan Moxie, strives to accommodate client requests where practical
and possible.
D. WRAP PROGRAM
Hilpan Moxie does not sponsor or participate in a wrap program.
E. CLIENT ASSETS MANAGED
As of June 18, 2026, Hilpan Moxie managed $100,359,897 in assets, with $71,241,067 on
a discretionary basis and $29,118,830 on a non-discretionary basis.
5. FEES AND COMPENSATION
A. FEES AND COMPENSATION
Financial Planning Services
Hilpan Moxie provides financial planning services for a flat-fee rate basis of $6,750. HMWM
solely reserves the right to charge lower fees at the firm’s discretion. Financial Planning
services will include preparation and research, areas to be specified and estimated in the written
agreement for services, as well as one plan revision. The fixed fee can be negotiated with the
client. All fees for planning services are agreed upon in advance in writing with the fees being
assessed quarterly in advance with the first payment due upon signing.
Financial Planning and Portfolio Management Services
For clients requesting financial planning and portfolio management services, it is offered for one
negotiated annual fee. The annual fee is based upon a percentage of assets under management
and it can range from .85% to 1.75%. The annual fee is calculated, accrued, and collected on a
quarterly basis in arrears. The annual fee can be negotiated based upon the complexity of the
client’s financial situation, the net worth of the individual or business, the estimate of hours
involved, including preparation and research, areas to be specified for financial planning, number
of accounts to be managed and size of the accounts to be managed. Also, the fee may be lower
for clients who do not request or want a financial plan.
Hilpan Moxie Wealth Management, LLC
Page 5 ADV Part 2A
Please refer to the tiered schedule:
Minimum Balance
Maximum Balance
Annual Fee
$0
$250,000
1.75%
$250,001
$450,000
1.50%
$450,001
$800,000
1.35%
$800,001
$1,000,000
1.25%
$1,000,001
$2,000,000
1.00%
$2,000,001
Up
0.85%
Comparable Services Disclosure
Clients should note that lower fees for comparable services may be available from other sources.
Termination of Advisory Services
A client may terminate this service for any reason within the first five (5) business days after
signing the contract without any cost or penalty. Thereafter, the contract may be terminated at
any time by giving ten (10) days written notice to Hilpan Moxie at 13 Woodland Drive, Irvine,
CA 92604. For financial planning services, after the first five (5) business days, written
termination will result in a pro-rated refund of any prepaid and unearned fee to the client based
upon the number of hours worked on the financial plan at rate of $300 per hour.
B. FEES DEDUCTION
The client will be asked to authorize Hilpan Moxie with the ability to deduct fees directly from
the client’s account. This authorization will be to deduct Hilpan Moxie’s management fee only.
Prior to deducting the fee, Hilpan Moxie will send a billing statement (invoice) to the client that
indicates the fee to be withdrawn and how it was calculated from the account. A client may
object to the deduction of the management fees from the Account by notifying Hilpan Moxie at
the address or telephone number shown on each billing statement or by notifying client’s
custodian. In addition to the billing statement, the client’s custodian will also send a quarterly
statement indicating the amount of fees withdrawn from the client’s Account. Hilpan Moxie
urges each client to carefully review such statements and compare them to the invoice provided.
C. OTHER FEES AND EXPENSES
Hilpan Moxie’s fee is separate and distinct from brokerage fees, transaction fees, and other
related costs and expenses that are incurred by the client. Clients may incur certain charges
imposed by custodians, brokers, third party investment and other third parties such as fees
Hilpan Moxie Wealth Management, LLC
Page 6 ADV Part 2A
charged by managers, custodial 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. Mutual funds and exchange traded funds also charge internal
management fees, as disclosed in a fund’s prospectus, which are separate and distinct from the
fee. Such charges, fees and commissions are exclusive of and in addition to our fee. We do not
receive any portion of these commissions, fees, and costs. For additional information on our
brokerage practices please see Item 12, below.
D. WHEN FEES ARE DEDUCTED
The fee is collected on a quarterly basis at the beginning of each quarter. Exigent circumstances
may require a closing date very near the end of the quarter.
E. OTHER SECURITIES COMPENSATION
Hilpan Moxie does not receive any other securities compensation for providing investment
advisory services to clients.
6. PERFORMANCE-BASED FEES AND SIDE BY SIDE MANAGEMENT
Hilpan Moxie 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).
7. TYPES OF CLIENTS
Hilpan Moxie serves a diverse clientele, including professionals across various industries. A
portion of the firm’s assets under management (AUM) consists of clients from the technology
sector, among others. Client meetings are conducted based on individual preferences, either in
person at designated locations or via secure video conferencing platforms.
Hilpan Moxie generally requires a minimum account size of $1,000,000 for new clients. However,
the firm may consider accounts below this threshold on a case-by-case basis at its sole discretion.
8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OFLOSS
A. METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
Hilpan Moxie’s method of analysis is a combination of technical, fundamental and asset
allocation.
Technical Analysis – Technical Analysis is a method of evaluating securities by analyzing
statistics generated by market activity, such as past prices and volume. Technical analysts do not
attempt to measure a security's intrinsic value, but instead use charts and other tools to identify
patterns that can suggest future activity. The risk associated with technical analysis is that there
is no broad consensus among technical traders on the best method of identifying future price
movements.
Hilpan Moxie Wealth Management, LLC
Page 7 ADV Part 2A
Fundamental Analysis – Fundamental analysis is a technique that attempts to determine a
security’s value by focusing on underlying factors that affect a company's actual business and its
future prospects. The analysis is performed on historical and present data. On a broader scope,
one can perform fundamental analysis on industries or the economy as a whole. The term refers
to the analysis of the economic well-being of a financial entity as opposed to only its price
movements. The risk associated with fundamental analysis is that despite that appearance that a
security is undervalued, it may not rise in value as predicted.
Asset Allocation – Asset Allocation is an investment strategy that aims to balance risk and
reward by apportioning a portfolio's assets according to an individual's goals, risk tolerance and
investment horizon among various asset classes. The asset classes typically include equities,
fixed-income, cash, and cash equivalents. Each class has different levels of risk and return, so
each will behave differently over time. The risk associated with asset allocation is that despite
being diversified there is no guarantee an account will rise in value.
B. RECOMMENDED SECURITIES AND INVESTMENT RISKS
Hilpan Moxie may use a variety of securities in a client’s portfolio. They may include, but are
not limited to, the following: Exchange Traded Funds (“ETFs”), Managed Mutual Funds such as
Large Cap Growth, Large Cap Value, Mid Cap Growth, Mid Cap Value, Small Cap Growth, and
Small Cap Value; ADRs; Stocks; Bonds; Domestic Real Estate; Foreign Real Estate;
Commodities; Options; Precious Metals; Preferred Stock; High Yield Debt; Emerging Markets;
Foreign Fixed Income; Domestic Fixed Income; Money Market Funds and Cash.
All investments bear different types and degrees of risk and investing in securities involves risk
of loss that clients should be prepared to bear. While Hilpan Moxie recommends various
securities that are designed to provide appropriate investment diversification, some investments
have significantly greater risks than others. Obtaining higher rates of return on investments
entails accepting higher levels of risk. Recommended investment strategies and securities seek
to balance risks and rewards to achieve investment objectives. Clients need to ask questions
about risks they do not understand. Hilpan Moxie encourages such on-going dialogue and would
be pleased to discuss them.
Hilpan Moxie strives to render its best judgment on behalf of its clients. Still, it cannot assure or
guarantee clients that investments will be profitable or assure that no losses will occur in an
investment portfolio. Past performance is an important consideration with respect to any
investment or investment adviser but is not a reliable predictor of future performance. Hilpan
Moxie continuously strives to provide outstanding long-term investment performance, but many
economic and market variables beyond our control can affect the performance of an investment
portfolio.
An investment could lose money over short or even long periods. A client should expect his/her
account value and returns to fluctuate within a wide range, like the fluctuations of the overall
stock and bond markets. The client’s account performance could be hurt by:
Hilpan Moxie Wealth Management, LLC
Page 8 ADV Part 2A
• Stock market risk: The chance that stock prices overall will decline. Stock markets tend to
move in cycles, with periods of rising stock prices and periods of falling stock prices.
• Interest rate risk: The chance that bond prices overall will decline because of rising interest
rates. Interest rate risk will vary for the client, depending on the amount of client assets
invested in bonds.
• Manager risk: The chance that the proportions allocated to the various securities will cause
the client’s account to underperform relevant to benchmarks or other accounts with a similar
investment objective.
• Active management fees risk: Active management strategies that involve frequent trading
generate higher transaction costs that diminish the fund's return. In addition, the short- term
capital gains resulting from frequent trades often have an unfavorable Income tax impact
when such funds are held in a taxable account.
• International Investing Risk: Investing in the securities of non-U.S. companies involves
special risks not typically associated with investing in U.S. companies. Foreign securities
tend to be more volatile and less liquid than investments in U.S. securities, and may lose
value because of adverse political, social, or economic developments overseas or due to
changes in the exchange rates between foreign currencies and the U.S. dollar. In addition,
foreign investments are subject to settlement practices, and regulatory and financial reporting
standards, that differ from those of the U.S.
• Terrorism Risk: The chance that stock domestic and international stock prices will
decline due to a terrorist event.
• Political Risk: The chance that a change in government may affect stock prices of
domestic or international stocks.
• Natural Risks: The chance that a natural catastrophe (earthquakes, hurricanes, etc.) may
affect stock prices of domestic or international stocks.
• Artificial Intelligence and Machine Learning Risk. Certain service providers utilized by the
Firm to service client accounts have artificial intelligence components. The use of artificial
intelligence and machine learning includes increased risk of data inaccuracies and security
vulnerabilities. Due to the rapid advancement of machine learning technologies, future risks
related to artificial intelligence are unpredictable. As a measure to mitigate these risks to our
clients, the Firm performs periodic due diligence of our service providers for assurance that the
service providers have appropriate controls in place to protect our clients’ information and to
limit data inaccuracies when artificial intelligence is used by the service provider.
9. DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events within the past 10-years that would be material to a client’s evaluation of the
Adviser or the integrity of its management. Hilpan Moxie has no disclosures.
Hilpan Moxie Wealth Management, LLC
Page 9 ADV Part 2A
10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
A. BROKER-DEALER AFFILIATIONS
Neither Hilpan Moxie, nor Don Hilario are registered or have an application pending to register, as
a broker-dealer or a registered representative of a broker-dealer.
B. FUTURES/COMMODITIES FIRM AFFILIATION
Neither Hilpan Moxie, nor Don Hilario are registered, or have an application pending to register as
a futures commission merchant, commodity pool operator, a commodity trading advisor, or an
associated person of the foregoing entities.
C. OTHER INDUSTRY AFFILIATIONS
Neither Hilpan Moxie, nor Don Hilario are affiliated with any other financial industry companies.
D. SELECTION AND MONITORING OF THIRD-PARTY INVESTMENT ADVISERS
Hilpan Moxie does not offer Selection and Monitoring of Third-Party Investment Advisers as a
service.
11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONSAND
PERSONAL TRADING
A. DESCRIPTION
Hilpan Moxie’s Code of Ethics establishes ideals for ethical conduct upon fundamental
principles of openness, integrity, honesty, and trust. Hilpan Moxie will provide a copy of its
Code of Ethics to any client or prospective client upon request.
Hilpan Moxie’s Code of Ethics covers all supervised persons, and it describes the high standard
of business conduct, and fiduciary duty to clients. The Code of Ethics includes provisions
relating to the confidentiality of client information, a prohibition on insider trading, a prohibition
of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of
certain gifts and business entertainment items, and personal securities trading procedures, among
other things. All supervised persons must acknowledge the terms of the Code of Ethics annually,
or as amended.
CERTIFIED FINANCAL PLANNER™ Professionals, such as Mr. Hilario, adheres to the
Certified Financial Planner Board of Standards, Inc. principles, which state:
Principle 1 – Integrity
Advisors will provide professional services with integrity. Integrity demands honesty and candor
which must not be subordinated to personal gain and advantage. Advisors are placed in positions
of trust by clients, and the ultimate source of that trust is the advisor’s personal integrity.
Allowance can be made for innocent error and legitimate differences of opinion, but integrity
cannot co-exist with deceit or subordination of one’s principles.
Hilpan Moxie Wealth Management, LLC
Page 10 ADV Part 2A
Principle 2 – Objectivity
Advisors will provide professional services objectively. Objectivity requires intellectual honesty
and impartiality. Regardless of the particular service rendered or the capacity in which an advisor
functions, advisors should protect the integrity of their work, maintain objectivity and avoid
subordination of their judgment.
Principle 3 – Competence
Advisors will maintain the necessary knowledge and skill to provide professional services
competently. Competence means attaining and maintaining an adequate level of knowledge and
skill, and application of that knowledge and skill in providing services to clients. Competence
also includes the wisdom to recognize the limitations of that knowledge and when consultation
with other professionals is appropriate or referral to other professionals necessary. Advisors
make a continuing commitment to learning and professional improvement.
Principle 4 – Fairness
Advisors will be fair and reasonable in all professional relationships. Fairness requires
impartiality, intellectual honesty and disclosure of material conflicts of interest. It involves a
subordination of one’s own feelings, prejudices, and desires so as to achieve a proper balance
of conflicting interests. Fairness is treating others in the same fashion that you would want to
be treated.
Principle 5 – Confidentiality
Advisors will protect the confidentiality of all client information. Confidentiality means ensuring
that information is accessible only to those authorized to have access. A relationship of trust and
confidence with the client can only be built upon the understanding that the client’s information
will remain confidential.
Principle 6 – Professionalism
Advisors will act in a manner that demonstrates exemplary professional conduct.
Professionalism requires behaving with dignity and courtesy to clients, fellow professionals, and
others in business-related activities. Advisors cooperate with fellow advisors to enhance and
maintain the profession’s public image and improve the quality of services.
Principle 7 – Diligence
Advisors will provide professional services diligently. Diligence is the provision of services in a
reasonably prompt and thorough manner, including the proper planning for, and supervision of,
the rendering of professional services.
B. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
Hilpan Moxie Wealth Management, LLC
Page 11 ADV Part 2A
Hilpan Moxie does not have a material interest in any securities.
PERSONAL TRADING
C.
On occasion the firm’s owner, Mr. Hilario, may buy or sell for his own accounts securities that
are the same as, similar to, or different than those that he recommends to his clients for purchase
or sale. Differences can arise due to variations in personal goals, investment horizons, risk
tolerance, and the timing of purchases and sales. Mr. Hilario attempts to mitigate the conflict of
interest to the best of his ability through the enactment of a code of ethics, trading policies, and
his fiduciary responsibilities. Nonetheless, Mr. Hilario generally attempts to place client
transactions ahead of proprietary trades. Mr. Hilario is aware of his fiduciary duty to his clients
and the prohibitions against the use of any insider information. Records of his proprietary
trading activities will be kept and made available to regulators to review on the premises.
BROKERAGE PRACTICES
12.
A. RECOMMENDATION CRITERIA
When Hilpan Moxie recommends custodians, it will seek broker-dealers who offer competitive
commission costs together with reliable services. A client’s choice of another broker-dealer is
acceptable if proven feasible.
Hilpan Moxie requests you utilize the brokerage and custodial services of Wells Fargo
Clearing (“WFCS”) who uses TradePMR to execute and trade securities. Clients who have non-
discretionary accounts with Hilpan Moxie may be asked to consider Charles Schwab & Co., Inc.,
(“Schwab”), Vanguard (“Vanguard”), or Empower (“Empower”), for which we have an existing
relationship. Hilpan Moxie and their custodians are not affiliated companies. In considering
which independent qualified custodian will be the best fit for Hilpan Moxie’s business model,
we are evaluating the following factors, which is not an all-inclusive list:
Financial strength
Reputation
Reporting capabilities
Execution capabilities
Pricing, and
Types and quality of research
Hilpan Moxie has and continues to recommend TradePMR for securities transactions. Hilpan
Moxie recognizes its fiduciary responsibility in negotiating brokerage commissions, assuring
best execution practices, and assuring adequate investment availability/inventory on behalf of
its clientele. It does not receive compensation with respect to execution of these trades. In some
instances, a client may incur a ticket charge for the sale and purchase of securities.
NOTE: Clients may be able to obtain lower commissions and fees from other brokers, and the
value of products, research and services given to the applicant is not a factor in determining the
selection of broker/dealers or the reasonableness of their commissions.
i. RESEARCH AND SOFT DOLLARS
Hilpan Moxie Wealth Management, LLC
Page 12 ADV Part 2A
“Soft dollars” are defined as a form of payment investment firms can use to pay for goods and
services such as subscriptions or research. When an investment firm gives its business to a
particular brokerage firm, the brokerage firm in return can agree to use some of its revenue to
pay for these types of services. Hilpan Moxie does not receive “soft dollars” from any vender,
service provider or custodian in exchange for its placement of brokerage services.
ii. BROKERAGE FOR CLIENT REFERRALS
Hilpan Moxie does not receive client referrals or any other incentive from any independent
broker-dealer for execution of client transactions.
iii. DIRECTED BROKERAGE
Some clients may direct Hilpan Moxie to a specific broker-dealer to execute securities
transactions for their accounts. When so directed, the firm may not be able to effectively
negotiate lower brokerage commissions or achieve best execution on clients’ transactions. This
can result in substantially higher fees, charges, or dealer concessions in one or more
transactions for the clients’ account because the Adviser cannot negotiate favorable prices.
B. TRADE AGGREGATION
Trading multiple accounts for the same security is referred to as aggregate or block trading.
When orders are aggregated, each participating account would receive the average share price
for the transaction and bear a proportionate share of all transaction costs, based upon each
account’s participation in the transaction, subject to the adviser’s discretion depending on
factual or market conditions. Clients participating in block trading may include proprietary or
related accounts. Such accounts are treated as client accounts and are neither given preferential
nor inferior treatment versus other client accounts. Allocations of orders among client accounts
must be made in a fair and equitable manner. Be advised, Hilpan Moxie does not currently
engage in aggregate or block trading.
REVIEW OF ACCOUNTS
13.
A. PERIODIC REVIEWS
Mr. Hilario, the owner, reviews each client’s statement from his/her custodian on a monthly
basis. In addition to this review, Mr. Hilario meets (by phone or in person) with clients on a
quarterly basis to discuss and review their accounts.
B. OTHER REVIEWS
Additional reviews are conducted periodically depending on market conditions, economic or
political events, or by changes in a client’s financial situation (such as retirement, termination of
employment, physical move, or inheritance).
C. REPORTS
A written financial plan is provided to each client at the end of the financial planning portion of
the end of the engagement. Portfolio Management clients receive at least quarterly statements
from their custodian. Hilpan Moxie urges clients to carefully review such statements.
Hilpan Moxie Wealth Management, LLC
Page 13 ADV Part 2A
14. CLIENT REFERRALS AND OTHER COMPENSATION
A. OTHER COMPENSATION
Hilpan Moxie does not receive extra compensation or any other economic benefit for providing
investment advice or other advisory services to clients.
B. CLIENT REFERRALS
Hilpan Moxie does not pay for client referrals or use solicitors.
15. CUSTODY
All client funds, securities and accounts are held at third-party custodians. Hilpan Moxie does
not take possession of a client’s securities.
Clients should receive quarterly statements from the broker dealer, bank or other qualified
custodian that holds and maintains client’s investment assets. Each client will also receive at
least quarterly an invoice from TradePMR that details all asset management fees charged to the
clients’ account. Hilpan Moxie urges clients to carefully review such statements.
16. INVESTMENT DISCRETION
Hilpan Moxie’s investment management services include discretionary authority, which is
granted when a client signs an investment management agreement granting that power. The
discretionary investment management agreement contains a limited power of attorney. The
agreement allows Hilpan Moxie to buy and/or sell selected securities, within the tolerance
agreed to by the client, and in the amounts it deems suited to the agreed upon portfolio structure.
It also allows Hilpan Moxie to place each such trade without the client’s prior approval. In all
cases, however, such discretion is to be exercised in a manner consistent with the stated
investment objectives for the particular client account, and any other investment policies,
limitation, or restrictions.
17. VOTING CLIENT SECURITIES
Hilpan Moxie will not be responsible for responding to proxies that are solicited with respect
securities held in clients' accounts. All proxy solicitation materials are sent directly to the client
from the issuing company. In the event a client has a question about a proxy solicitation, the
client should contact the issuer of the security.
18. FINANCIAL INFORMATION
A. BALANCE SHEET
Hilpan Moxie does not require or solicit prepayment of more than $1,200 in fees per client,
six months or more in advance. Therefore, Hilpan Moxie does not have to provide a balance
sheet.
Hilpan Moxie Wealth Management, LLC
Page 14 ADV Part 2A
B. FINANCIAL CONDITION
Registered investment advisers are required in this Item to provide to clients with certain
financial information or disclosures about the firm’s financial condition. Hilpan Moxie does not
have a financial commitment that impairs its ability to service its clients.
C. BANKRUPTCY
Neither Hilpan Moxie, nor Don Hilario, have ever been the subject of a bankruptcy proceeding.
19. REQUIREMENTS FOR STATE-REGISTERED ADVISERS
This section is not applicable because the firm is registered with the U.S. Securities and Exchange
Commission.
(END)
Hilpan Moxie Wealth Management, LLC
Page 15 ADV Part 2A