HMV WEALTH ADVISORS, LLC

Item 1 – Cover Page HMV Wealth Advisors, LLC 333 Texas Street, Suite 1525 Shreveport, LA 71101 318-517-6255 www.hmvwealth.com September 26, 2025 This Brochure provides information about the qualifications and business practices of HMV Wealth Advisors, LLC (“HMVWA”). If you have any questions about the contents of this Brochure, please contact us at the number listed above. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. HMVWA is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. The oral and written communications of an adviser provide you with information about which you determine to hire or retain an adviser. Additional information about HMVWA is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for HMVWA is 297747.  Item 2 – Material Changes This item of the Brochure discusses only specific material changes that have been made to the Brochure since the last annual update and provides clients with a summary of such changes. We made the following material change to this Brochure: • • Item 4 and Item 10 were updated to disclose our increased use of Focus Partners Advisor Solutions. Item 4 and Item 5 were updated to disclose our use of independent managers and how they charge their fees. Item 10 was updated to disclose our affiliate, HMV Retirement Plan Advisors, LLC. • We will also provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochure may be requested by contacting us at the phone number listed in Item 1. Additional information about HMVWA is also available via the SEC’s website at www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with HMVWA who are registered, or are required to be registered, as investment adviser representatives of HMVWA. Date of Brochure: 09/26/2025 Date of Most Recent Annual Updating Amendment: 09/26/2025 2  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 ........................................................................................................ 6 Item 6 – Performance-Based Fees and Side-by-Side Management ........................................................ 7 Item 7 – Types of Clients .................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................... 8 Item 9 – Disciplinary Information ...................................................................................................... 10 Item 10 – Other Financial Industry Activities and Affiliations ............................................................... 11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 12 Item 12 – Brokerage Practices ........................................................................................................... 13 Item 13 – Review of Accounts ........................................................................................................... 14 Item 14 – Client Referrals and Other Compensation ........................................................................... 15 Item 15 – Custody ............................................................................................................................ 16 Item 16 – Investment Discretion ....................................................................................................... 16 Item 17 – Voting Client Securities ..................................................................................................... 17 Item 18 – Financial Information ........................................................................................................ 17 Brochure Supplements (provided to clients) 3  Item 4 – Advisory Business HMV Wealth Advisors, LLC (“HMVWA”) is a Limited Liability Company and is owned by the accounting firm Heard, McElroy & Vestal, LLC. HMVWA has been providing advisory services since 2018. As of June 30, 2025, HMVWA managed $464,771,467 on a discretionary basis. Additionally, HMVWA advised on an additional $34,921,514 of self-directed retirement account assets. HMVWA offers a variety of investment advisory services to our clients on a discretionary basis, as laid out in the advisory agreement. HMVWA’s services include investment management. Prior to providing advisory services, clients are required to enter into a written agreement with HMVWA. Investment Management Services HMVWA manages investment portfolios for individuals, trusts, charitable organizations, business, and qualified retirement plans. HMVWA will work with a client to determine the client’s investment objectives and investor risk profile and will design a written investment policy statement (“IPS”). HMVWA uses investment and portfolio allocation software to evaluate alternative portfolio designs. HMVWA evaluates the client’s existing investments with respect to the client’s IPS. HMVWA works with new clients to develop a plan to transition from the client’s existing portfolio to the portfolio recommended by HMVWA. HMVWA will then continuously monitor the client’s portfolio holdings and the overall asset allocation strategy and hold review meetings with the client regarding the portfolio as necessary. HMVWA will typically create portfolios of no-load mutual funds, exchange-traded funds (“ETFs”), and high-quality fixed income investments, and may use model portfolios if the models match the client’s investment policy. HMVWA primarily recommends mutual funds that follow a passive asset class investment philosophy with low holdings turnover. HMVWA will allocate the client’s assets among various investments taking into consideration the overall management style selected by the client in the IPS. Client portfolios may also include some individual equity securities in situations where disposition of these securities would present an overriding tax implication or the client specifically requests they be retained for a personal reason. These situations will be specifically identified in the client’s IPS. HMVWA manages client portfolios on a discretionary and non-discretionary basis according to the IPS. A client may impose any reasonable restrictions on HMVWA’s discretionary authority, including restrictions on the types of securities in which HMVWA may invest client’s assets and on specific securities, which the client may believe to be appropriate. HMVWA has retained Focus Partners Advisor Solutions (“FPAS”) to act as a discretionary sub-adviser. FPAS shall provide various model asset allocation portfolios (each a “Portfolio”, collectively “Portfolios”) for selection by HMVWA. Each Portfolio strives to achieve long-term risk and return objectives through diversification among multiple asset classes using investment options available to FPAS, which may 4  include, but are not limited to, mutual funds and/or ETFs from Dimensional Fund Advisors LP, Bridgeway Capital Management, Inc., AQR Capital Management, LLC, The Vanguard Group, Inc., Stoneridge Asset Management, LLC, or other providers selected by FPAS. Each Portfolio is designed to meet a particular investment goal which HMVWA has determined is suitable based on the client’s circumstances. Once the appropriate Portfolio(s) have been determined, the Portfolio(s) will continuously be managed based on the Portfolio(s)’ goal and FPAS will have the discretionary authority to manage the Portfolio(s), including periodically rebalancing. However, HMVWA, on behalf of its client, will have the opportunity to place reasonable restrictions on the types of investments to be held in the Portfolio(s). Should material life events occur, clients should immediately contact HMVWA to determine if changes to a Portfolio and the allocation of the assets held in the Portfolio are necessary. If appropriate for a client, HMVWA may allocate a portion of a portfolio to an independent third-party investment adviser (“separate account manager”) for separate account management based upon individual client circumstances and objectives, including, but not limited to, client account size, investment strategy, and tax circumstances. On an ongoing basis, HMVWA will answer client inquiries regarding their accounts and review periodically with clients the performance of their accounts. HMVWA will periodically, and at least annually, review clients’ IPS and discuss the rebalancing of each client portfolio to the extent appropriate. HMVWA will provide investment managers with any updated client financial information or account restrictions necessary for the investment manager to provide sub-advisory services. In addition to managing the client’s investment portfolio, HMVWA may consult with clients on various financial areas including income and estate tax planning, business sale structures, college financial planning, retirement planning, insurance analysis, personal cash flow analysis, establishment and design of retirement plans and trust designs, among other things. HMVWA does not participate in or sponsor any wrap fee programs. Employee Benefit Retirement Plan Services HMVWA provides advisory services to participant-directed retirement plans through third-party administrators. These administrators offer plan sponsors the ability to provide their participants with daily account access, valuation, and investment education. HMVWA will analyze the plan’s current investment platform and assist the plan in creating an IPS defining the types of investments to be offered and the restrictions that may be imposed. HMVWA will recommend investment options to achieve the plans objectives, provide participant education meetings, and monitor the performance of the plan’s investment vehicles. HMVWA will recommend changes in the plan’s investment vehicles as appropriate from time to time. HMVWA generally will review the plan’s investment vehicles and investment policy, as necessary. For certain retirement plans, HMVWA also works in coordination and support with FPAS. Retirement plan clients will engage both HMVWA and FPAS. FPAS will provide the client additional discretionary 5  investment management services and will exercise discretionary authority to select the plan investments made available to the plan’s participants according to the goals and investment objectives of the plan. Item 5 – Fees and Compensation In certain circumstances, all fees, portfolio minimums, and their applications to family circumstances may be negotiable. HMVWA has contracted with FPAS for services including trade processing, collection of management fees, record maintenance, report preparation, marketing assistance, and research. HMVWA has also contracted with FPAS for sub-advisory services with respect to client portfolios. HMVWA pays a fee for FPAS’s services based on management fees paid to HMVWA on portfolios which use FPAS. The fee paid by HMVWA to FPAS consists of a portion of the fees paid by clients to HMVWA and varies based on the total client assets administered and/or sub-advised by FPAS through HMVWA. These fees are not separately charged to clients. The fee charged by HMVWA to its clients includes all sub-advisory fees charged by FPAS. The specific manner in which fees are charged by HMVWA is established in the client’s written agreement with HMVWA. Investment Management clients will be billed in advance at the beginning of each calendar quarter based on the value of the client’s account(s) at the end of the previous quarter. Market value is based on independent third-party sources or fair market value in the absence of market value. Fees for new portfolios will be initially prorated based on the number of days remaining in the quarter in which the portfolio is incepted (date of first trade). Client account balances on which HMVWA calculates fees may vary from account custodial statements based on independent valuations and other accounting variances, including mechanisms for including accrued interest on account statements. For Investment Management Services and Employee Benefit Retirement Plan Services, HMVWA will request authority from the client to receive quarterly payments directly from the client’s account held by an independent third-party custodian. Clients may provide written limited authorization to HMVWA or its designated service provider, FPAS, to withdraw fees from the account. Clients will receive custodial statements showing the advisory fees debited from their account(s). Certain third-party administrators and/or recordkeepers will calculate and debit HMVWA’s fee and remit such fee to HMVWA. A client agreement may be canceled at any time, by either party, for any reason upon receipt of thirty (30) days’ written notice. Upon termination of any account, the fees for the quarter will be prorated to the effective date of the termination and any prepaid fees with respect to the period after the effective date of the termination will be refunded. The client has the right to terminate an agreement without penalty within five (5) business days after entering into the agreement. HMVWA’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third-party investment advisers, and other third parties such as fees charged by managers, custodial fees, 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 ETFs also charge internal 6  management fees, which are disclosed in the fund’s prospectus. These fees will generally include a management fee and other fund expenses. All fees paid to HMVWA for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and ETFs to their shareholders. Such charges, fees, and commissions are exclusive of and in addition to HMVWA’s fee, and HMVWA shall not receive any portion of these commissions, fees, and costs. Investment Management Services In general, the annual fee for Investment Management Services will be charged as a percentage of assets under management, according to the schedule below. The specific fee charged is included in the client’s advisory agreement. Assets Under Management On the first $1,000,000* On the next $1,000,000 On the next $1,000,000 On the next $2,000,000 On all amounts thereafter Annual Fee (%) 1.00% 0.70% 0.50% 0.40% 0.35% *HMVWA’s minimum portfolio size is $1,000,000 All accounts for members of the client’s family (husband, wife and dependent children) or related business may be assessed fees based on the total balance of all accounts. If an independent third-party adviser is utilized for separate account management, that adviser can charge its own management fee. All fees and expenses charged by a separate account manager are separate and distinct from HMVWA’s management fee and are withdrawn from the client’s account by the separate account manager. Employee Benefit Retirement Plan Services In general, the annual fee for plan services will be charged as a percentage of assets within the plan. Assets Under Management FPAS’s Annual Fee (%) Total Annual Fee On the first $1,000,000* On the next $4,000,000 On the next $5,000,000 On all amounts thereafter HMVWA’s Annual Fee 0.70% 0.45% 0.25% 0.15% 0.20% 0.15% 0.08% 0.05% 0.90% 0.60% 0.33% 0.20% Item 6 – Performance-Based Fees and Side-by-Side Management HMVWA does not charge any performance-based fees (fees based on a share of capital gains or on capital appreciation of the assets of a client). No fees will be charged on the basis of income or capital gains or capital appreciation of the funds or any portion of the funds of a client. 7  Item 7 – Types of Clients HMVWA provides services to individuals, high-net-worth individuals, trusts, estates, partnerships, corporations, other entities, charitable organizations and retirement plans. As stated above in Item 5, the minimum portfolio size for clients working with HMVWA is generally $1,000,000 for Investment Management Services. A minimum of $500,000 is generally required for management services of portfolios of individual fixed income securities. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategy HMVWA’s services are based on long-term investment strategies incorporating the principles of Modern Portfolio Theory. HMVWA’s investment approach is rooted in the theory that markets are “efficient” over periods of time and that investors’ long-term returns are determined principally by asset allocation decisions rather than market timing or stock picking. HMVWA recommends diversified portfolios, principally through the use of passively managed, broadly traded, asset class open-end mutual funds, ETFs, and fixed income securities to implement this investment strategy. Although all investments involve risk, HMVWA’s investment advice seeks to limit risk through broad diversification among asset classes and, as appropriate, the investment directly in conservative fixed income securities. HMVWA’s investment philosophy is designed for investors who desire a buy and hold strategy. Frequent trading of securities increases brokerage and other transaction costs that HMVWA’s strategy seeks to minimize. HMVWA recommends, as appropriate, certain alternatives that are still registered investment company funds for select clients. While HMVWA is generally skeptical of most alternative investment strategies, HMVWA believes there are a few alternative strategies accessed in mutual fund form that can enhance portfolio forward-looking forecasted returns and/or reduce portfolio volatility. Allocations here, however, should be relatively modest since some of these strategies have relatively high expense ratios and can be tax inefficient. Clients may hold or retain other types of assets as well, and HMVWA may offer advice regarding those various assets as a part of its services. Advice regarding such assets will generally not involve asset management services but may help to more generally assist the client. HMVWA’s strategies do not utilize securities that we believe would be classified as having any unusual risks and we do not recommend frequent trading, which can increase brokerage and other costs and taxes. HMVWA receives supporting research from FPAS and from other consultants, including economists affiliated with Dimensional Fund Advisors (“DFA”). HMVWA utilizes DFA-sponsored securities in client portfolios. DFA-sponsored securities follow a passive asset class philosophy with low holdings turnover. DFA provides historical market analysis, risk/return analysis, and continuing education to HMVWA. 8  Analysis of a Client’s Financial Situation In the development of investment plans for clients, including the recommendation of an appropriate asset allocation, HMVWA relies on an analysis of the client’s financial objectives, current and estimated future resources, and tolerance for risk. To derive a recommended asset allocation, HMVWA may use a Monte Carlo simulation, a standard statistical approach for dealing with uncertainty. As with any other method used to make projections into the future, there are several risks associated with this method, which may result in the client not being able to achieve their financial goals. They include: • The risk that expected future cash flows will not match those used in the analysis; • The risk that future rates of return will fall short of the estimates used in the simulation; • The risk that inflation will exceed the estimates used in the simulation; and • For taxable clients, the risk that tax rates will be higher than what was assumed in the analysis. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. All investments present the risk of loss of principal – the risk that the value of the security (mutual fund, ETF, individual bond), when sold or otherwise disposed of, may be less than the price paid for the securities. Even when the value of the securities when sold is greater than the price paid, there is the risk the appreciation will be less than inflation. In other words, the purchasing power of the proceeds may be less than the purchasing power of the original investment. The mutual funds and ETFs utilized by HMVWA may include funds invested in domestic and international equities, including real estate investment trusts (“REITs”), corporate and government fixed income securities and commodities. Equity securities may include large capitalization, medium capitalization, and small capitalization stocks. Mutual funds and ETF shares invested in fixed income securities are subject to the same interest rate, inflation, and credit risks associated with the underlying bond holdings. Among the riskiest mutual funds and ETFs used in HMVWA’s investment strategies are the U.S. and International small capitalization and small capitalization value funds, emerging markets funds, and commodity futures funds. Conservative fixed income securities have lower risk of loss of principal, but most bonds (with the exception of Treasury Inflation Protected Securities (“TIPS”)) present the risk of loss of purchasing power through lower expected return. This risk is greatest for longer-term bonds. Certain funds utilized by HMVWA may contain international securities. Investing outside of the United States involves additional risks, such as currency fluctuations, periods of illiquidity, and price volatility. These risks may be greater with investments in developing countries. Alternative Fund Risk Certain alternative funds (registered under the Investment Company Act of 1940) utilized by HMVWA may employ use of derivatives, options, futures and/or short sales. Use of derivatives, options or futures by alternative funds may be for purposes of gaining exposure to a particular asset group, for hedging 9  purposes or for leverage purposes. The use of derivatives, options and futures exposes the funds to additional risks and transaction costs. In addition, if the fund uses leverage through activities such as entering into short sales or purchasing derivative instruments, there are additional risks, including the fund having the risk that losses may exceed the net assets of the fund. The net asset value of a fund while employing leverage will be more volatile and sensitive to market movements. Clients should carefully review the fund’s prospectus to more fully understand the risk of funds employing the use of derivatives, options, futures and/or short sales. Investments in these funds should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some or all of the investment. Interval Fund Risk An interval fund is a type of closed-end fund utilizing shares that do not trade on the secondary market. Instead, the fund periodically offers to buy back a percentage of outstanding shares at net asset value. The rules for interval funds, along with the types of assets held, make this investment largely illiquid compared to other funds. The primary reasons for investors to consider investing in interval funds HMVWA may utilize include, but are not limited to, gaining exposure to certain risk categories that provide diversified sources of expected returns, part of which may be in the form of illiquidity premiums. Access to the intended risk and expected return characteristics may not otherwise be available in more liquid, traditional investment vehicles. Where appropriate, HMVWA may utilize certain interval funds structured as non-diversified, closed-end management investment companies registered under the Investment Company Act of 1940. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired, and the fund may suspend or postpone purchases. Clients should carefully review the fund’s prospectus to more fully understand the interval fund structure and the corresponding liquidity risks. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk, and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some or all of the investment. The risk of loss described herein should not be considered to be an exhaustive list of all the risks which client should consider. More information about the risks of any particular market sector can be reviewed in representative mutual fund prospectuses within each applicable sector. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of HMVWA or the integrity of HMVWA’s management. HMVWA has no information applicable to this Item. 10  Item 10 – Other Financial Industry Activities and Affiliations HMVWA will disclose any material conflicts of interest related to HMVWA, our representatives, or any associates which could be reasonably expected to affect the decision-making of our clients. Heard, McElroy & Vestal, LLC Heard, McElroy & Vestal, LLC is an affiliated licensed accounting firm which offers tax and accounting services. There are no referral arrangements between Heard, McElroy & Vestal, LLC and HMVWA. Heard, McElroy & Vestal, LLC may recommend HMVWA to its clients in need of advisory services. HMVWA may recommend Heard, McElroy & Vestal, LLC to advisory clients in need of the services provided by Heard, McElroy & Vestal, LLC. Heard, McElroy & Vestal, LLC’s services are separate and distinct from the advisory services of HMVWA and are provided for separate and typical compensation. No HMVWA client is obligated to use Heard, McElroy & Vestal, LLC for any services, and no Heard, McElroy & Vestal, LLC client is obligated to use HMVWA for advisory services. All services provided by Heard, McElroy & Vestal, LLC are provided subject to a separate agreement, outlining the offering and pricing agreed to in advance. HMV Retirement Plan Advisors, LLC HMV Retirement Plan Advisors is a third-party administrator, wholly owned by Heard, McElroy & Vestal, LLC. There are no referral arrangements between HMV Retirement Plan Advisors and HMVWA. HMV Retirement Plan Advisors may recommend HMVWA to its clients in need of advisory services. HMVWA may recommend HMV Retirement Plan Advisors to advisory clients in need of the services provided by HMV Retirement Plan Advisors. HMV Retirement Plan Advisors services are separate and distinct from the advisory services of HMVWA and are provided for separate and typical compensation. No HMVWA client is obligated to use HMV Retirement Plan Advisors for any services, and no HMV Retirement Plan Advisors client is obligated to use HMVWA for advisory services. All services provided by HMV Retirement Plan Advisors are provided subject to a separate agreement, outlining the offering and pricing agreed to in advance. Individual Insurance License Roderick Williams, in his individual capacity, is a licensed independent insurance agent. Mr. Williams does not actively recommend or provide insurance product recommendations to any clients of HMVWA. Focus Partners Advisor Solutions As described above in Item 4, HMVWA will exercise discretionary authority provided by the client to select an independent third-party investment manager for the management of portfolios. HMVWA has selected Focus Partners Advisor Solutions (“FPAS”) for such sub-advisory management and also 11  contracts with FPAS for back-office services. HMVWA has a fiduciary duty to select qualified and appropriate managers in the client’s best interest and believes FPAS effectively provides both the back- office services that assist with HMVWA’s overall investment advisory practice and sub-advisory services. HMVWA continuously analyzes and assesses the use of FPAS in this capacity. While HMVWA has a contract with FPAS governing a time period for back-office services, HMVWA has no such fixed commitment for the selection of FPAS for sub-advisory services and may select another independent manager for clients upon reasonable notice to FPAS. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading HMVWA has adopted a Code of Ethics for all Supervised Persons of the firm, describing its high standard of business conduct and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment, and personal securities trading procedures, among other things. All Supervised Persons of HMVWA must acknowledge the terms of the Code of Ethics initially, annually, and as amended. HMVWA and individuals associated with HMVWA may buy or sell securities identical to those recommended to clients for their personal accounts. In addition, any related person(s) may have an interest or position in a certain security(ies) which may also be recommended to a client. It is the express policy of HMVWA that no person employed by HMVWA will take inappropriate advantage of their positions and the interests of client accounts will be placed first at all times. HMVWA anticipates that, in appropriate circumstances, consistent with clients’ investment objectives, it will cause accounts for which HMVWA has management authority over to effect, and will recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which HMVWA, its affiliates and/or clients, directly or indirectly, have a position of interest. HMVWA’s employees and persons associated with HMVWA are required to follow HMVWA’s Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors, and employees of HMVWA and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for HMVWA’s clients. The Code of Ethics is designed to ensure the personal securities transactions, activities and interests of the employees of HMVWA will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code, certain classes of securities have been designated as exempt transactions, based upon a determination that these would not materially interfere with the best interests of HMVWA’s clients. In addition, the Code requires pre-clearance of certain transactions. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics. 12  HMVWA will provide a complete copy of its Code of Ethics to any client or prospective client upon request. It is HMVWA’s policy that the firm will not affect any principal or agency cross securities transactions for client accounts. HMVWA will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. A principal transaction may also be deemed to have occurred if a security is crossed between an affiliated private fund and another client account. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may also arise where an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer. Item 12 – Brokerage Practices HMVWA arranges for the execution of securities transactions with the operational assistance of FPAS. Through FPAS, HMVWA participates in the Fidelity Institutional Wealth Services program, sponsored by Fidelity Brokerage Services LLC, (“Fidelity”). Fidelity is an unaffiliated SEC-registered broker dealer and FINRA-member broker dealer. Fidelity offers services which include custody of securities, trade execution, clearance and settlement transactions. Fidelity will generally be recommended to advisory clients for the execution of mutual fund, ETF, and equity securities transactions. HMVWA regularly reviews this program to ensure that its recommendations are consistent with its fiduciary duty. This trading platform is essential to HMVWA’s service arrangements and capabilities, and HMVWA may not accept clients who direct the use of other brokers. As part of this program, HMVWA receives benefits that it would not otherwise receive if it did not offer investment advice. See additional disclosure about these benefits in Item 14 of this Brochure. Because HMVWA will not request the discretionary authority to determine the broker dealer to be used or the commission rates to be paid for mutual fund and equity securities transactions, clients must direct HMVWA as to the broker dealer to be used. In directing the use of a particular broker or dealer, it should be understood that HMVWA will not have the authority to negotiate commissions among various brokers or obtain volume discounts, and thus best execution may not be achieved. Not all investment advisers require clients to direct the use of specific brokers. HMVWA will not exercise authority to arrange client transactions in fixed income securities. Clients will provide this authority to an independent manager retained by HMVWA on client’s behalf by designating the portfolio manager with trading authority over the client’s brokerage account. HMVWA has selected FPAS as its independent manager in this regard. Clients will be provided with the Disclosure Brochure (Form ADV Part 2) of FPAS. In this situation, HMVWA will monitor the trading services provided by FPAS to assess the quality of broker dealer services and client fixed income transactions. Such factors shall be taken into account: the 13  reasonableness of brokerage costs, commissions and mark up / mark downs, the broker dealer’s ability to provide professional services, competitive execution, and other services that help HMVWA in providing investment management services to clients. Through FPAS’s trading desk, client trades may be blocked with transactions by other investment advisers participating in the FPAS program to achieve better pricing and commission costs. This means an HMVWA client’s order may be aggregated with an order with a client who is not an HMVWA client. While this will generally benefit clients, certain trades may only be partially filled, in which case a client’s order may not be fulfilled. Partially filled orders will be allocated on the first orders received by FPAS for inclusion in the block trades. HMVWA generally does not aggregate any client transactions in mutual funds or other securities. Client accounts are individually reviewed and managed, and transaction costs are not saved by aggregating orders in almost all circumstances where HMVWA arranges transactions. HMVWA does not have any arrangements to compensate any broker dealer for client referrals. When trading client accounts, errors may occur. HMVWA does not maintain any client trade error gains. HMVWA makes clients whole with respect to any trade error losses incurred by client and caused by HMVWA. Employee Benefit Plan Services: For non-pooled employee benefit plans, HMVWA does not arrange for the execution of securities transactions for plans as a part of this service. Transactions are executed directly through employee plan participation. Item 13 – Review of Accounts Reviews Investment Management Services Portfolios are supervised continuously and formally reviewed at least annually by an investment adviser representative of HMVWA. The review process contains each of the following elements: • Assessing client goals and objectives; • Evaluating the employed strategy(ies); • Monitoring the portfolio(s); and • Addressing the need to rebalance. Additional portfolio reviews may be triggered by any of the following events: • A specific client request; • A change in client goals and objectives; • An imbalance in portfolio asset allocation; and 14  • Market/economic conditions. For accounts on the FPAS platform, certain account review responsibilities are delegated to FPAS as described above in Item 4. Employee Benefit Plan Services Plan assets are reviewed on a quarterly basis or as otherwise agreed between the parties, and according to the standards and situations described above for investment management services. Reports Investment Management Services All clients will receive written quarterly performance reports from HMVWA that summarize the client’s portfolio and asset allocation. Clients will also receive at least quarterly statements from their account custodian(s), which will outline the client’s current positions and current market value. Employee Benefit Plan Services Plan sponsors are provided with quarterly information and annual performance reviews from HMVWA. In addition, plan participant education information may also be provided to the Plan Sponsor or Administrator for distribution to participants of the Plan. Item 14 – Client Referrals and Other Compensation As indicated in Item 12, Fidelity provides HMVWA with access to services that are not available to retail investors. These services are generally available to independent investment advisers on an unsolicited basis at no charge to them. These services benefit HMVWA but may not benefit its clients’ accounts. Many of the products and services assist HMVWA in managing and administering clients’ accounts. These include software and other technology that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of HMVWA’s fee from its clients’ accounts, and assist with back-office functions, recordkeeping, and client reporting. Many of these services generally may be used to service all or a substantial number of HMVWA’s accounts. Fidelity also makes available to HMVWA other services intended to help HMVWA manage and further develop its business enterprise. These services may include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, and marketing. HMVWA does not, however, enter into any commitments with Fidelity for transaction levels in exchange for any services or products. While as a fiduciary, HMVWA endeavors to act in its clients’ best interests, HMVWA’s recommendation that clients maintain their assets in accounts at Fidelity may be based in part on the benefit to HMVWA and not solely on the nature, cost, or quality of custody and brokerage services provided, which creates a conflict of interest. 15  HMVWA also receives software from DFA, which HMVWA utilizes in forming asset allocation strategies and producing performance reports. DFA also provides continuing education for HMVWA personnel. These services are designed to assist HMVWA in planning and designing its services for business growth. Because DFA provides these services to HMVWA, this creates a conflict of interest as we have an incentive to recommend DFA funds. As disclosed in Item 10 above, our affiliated entities may recommend HMVWA to their clients in need of advisory services. HMVWA may recommend our affiliates to advisory clients in need of their services. We have an incentive to recommend our affiliates to you, which is a conflict of interest. HMVWA does not engage in any referral arrangements. Item 15 – Custody HMVWA is deemed to have custody due to a trustee position and is subject to an annual surprise custody examination. HMVWA is also considered to have limited custody of client assets due to the ability to deduct its advisory fees. In order to prevent HMVWA from being deemed as maintaining custody of client assets, we will ensure the following: • Clients provide written authorization for HMVWA to deduct advisory fees from the custodial accounts in the client’s advisory agreement; and • HMVWA has the reasonable belief the account custodian sends at least quarterly statements directly to the client showing all disbursements from the custodial account, including HMVWA’s advisory fee. Clients should receive at least quarterly statements from the broker dealer, bank, or other qualified custodian that holds and maintains client’s investment assets. HMVWA urges you to carefully review such statements and compare such official custodial records to the account statements that we may provide to you. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 16 – Investment Discretion HMVWA requests that it be provided with written authority to determine which securities and the amounts of securities that are bought and sold. For sub-advisory services, this authority will include the discretion to retain a third-party independent manager. Any limitations on this discretionary authority shall be included in this written authority statement. Clients may change these limitations as required. Such amendments shall be submitted in writing. When selecting securities and determining amounts, HMVWA observes the investment policies, limitations and restrictions of the clients. Investment guidelines and restrictions must be provided to HMVWA in writing. 16  Item 17 – Voting Client Securities Proxy Voting As a matter of firm policy and practice, HMVWA does not accept the authority to and does not vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Clients will receive applicable proxies directly from the issuer of securities held in client’s account(s). HMVWA, however, may provide advice to clients regarding the clients’ voting of proxies. Class Actions, Bankruptcies and Other Legal Proceedings Clients should note that HMVWA will neither advise nor act on behalf of clients in legal proceedings involving companies whose securities are held or previously were held in the clients’ account(s), including, but not limited to, the filing of “Proofs of Claim” in class action settlements. If desired, clients may direct HMVWA to transmit copies of class action notices to the client or third party. Upon such direction, HMVWA will make commercially reasonable efforts to forward such notices in a timely manner. Item 18 – Financial Information Registered investment advisers are required in this Item to provide certain financial information or disclosures about HMVWA’s financial condition. HMVWA does not require or solicit pre-payment of more than $1,200 in fees per client, six (6) months or more in advance. HMVWA has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. 17