HOFFMAN, ALAN N. INVESTMENT MANAGEMENT

F O R M A D V P A R T 2 A D I S C L O S U R E B R O C H U R E Hoffman, Alan N. Investment Management Office Address: 40 William St Unit 604 Wellesley, MA 02481 Tel: 617-308-5087 alanhoffman@icloud.com Website: www.anhinvest.com J A N U A R Y 2 1 , 2 0 2 6 This brochure provides information about the qualifications and business practices of Hoffman, Alan N. Investment Management. Being registered as a registered investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 617-308-5087. 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. Additional information about Hoffman, Alan N. Investment Management (CRD #109454) is available on the SEC’s website at www.adviserinfo.sec.gov i  Item 2: Material Changes Annual Update Material Changes since the Last Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Since the last filing of this brochure on January 24, 2025, the following changes have been • made: Full Brochure Available Item 4 has been updated with the firm’s most recent assets under management calculation. . This Firm Brochure being delivered is the complete brochure for the Firm. ii  Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 1: Cover Page Item 2: Material Changes .................................................................................................................... ii Annual Update ................................................................................................................................................................... ii Material Changes since the Last Update.................................................................................................................. ii Item 3: Table of Contents ................................................................................................................... iii Full Brochure Available .................................................................................................................................................. ii Item 4: Advisory Business .................................................................................................................. 1 Firm Description ............................................................................................................................................................... 1 Types of Advisory Services ........................................................................................................................................... 1 Client Tailored Services and Client Imposed Restrictions ............................................................................... 1 Wrap Fee Programs ......................................................................................................................................................... 1 Item 5: Fees and Compensation ....................................................................................................... 1 Client Assets under Management .............................................................................................................................. 1 Method of Compensation and Fee Schedule .......................................................................................................... 1 Client Payment of Fees ................................................................................................................................................... 2 Additional Client Fees Charged ................................................................................................................................... 2 Prepayment of Client Fees ............................................................................................................................................ 2 Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 3 External Compensation for the Sale of Securities to Clients ........................................................................... 3 Item 7: Types of Clients ....................................................................................................................... 3 Sharing of Capital Gains ................................................................................................................................................. 3 Description .......................................................................................................................................................................... 3 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 3 Account Minimums .......................................................................................................................................................... 3 Methods of Analysis ......................................................................................................................................................... 3 Investment Strategy ........................................................................................................................................................ 3 Item 9: Disciplinary Information ..................................................................................................... 6 Security Specific Material Risks .................................................................................................................................. 4 Criminal or Civil Actions ................................................................................................................................................ 6 Administrative Enforcement Proceedings ............................................................................................................. 6 iii  Item 10: Other Financial Industry Activities and Affiliations ............................................... 6 Self- Regulatory Organization Enforcement Proceedings ............................................................................... 6 Broker-Dealer or Representative Registration .................................................................................................... 6 Futures or Commodity Registration ......................................................................................................................... 6 Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................... 6 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ................ 6 Trading ..................................................................................................................................................... 7 Code of Ethics Description ............................................................................................................................................ 7 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest.... 7 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest ... 7 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Item 12: Brokerage Practices ........................................................................................................... 8 Transactions and Conflicts of Interest ..................................................................................................................... 8 Factors Used to Select Broker-Dealers for Client Transactions .................................................................... 8 Item 13: Review of Accounts ........................................................................................................... 11 Aggregating Securities Transactions for Client Accounts ............................................................................. 11 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ............................................................................................................................................................................. 11 Review of Client Accounts on Non-Periodic Basis ........................................................................................... 11 Item 14: Client Referrals and Other Compensation ................................................................ 11 Content of Client Provided Reports and Frequency ........................................................................................ 11 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ............................................................................................................................................................................... 11 Item 15: Custody .................................................................................................................................. 12 Advisory Firm Payments for Client Referrals .................................................................................................... 12 Item 16: Investment Discretion ..................................................................................................... 12 Account Statements ...................................................................................................................................................... 12 Item 17: Voting Client Securities ................................................................................................... 12 Discretionary Authority for Trading...................................................................................................................... 12 Item 18: Financial Information ...................................................................................................... 13 Proxy Votes ...................................................................................................................................................................... 12 Balance Sheet .................................................................................................................................................................. 13 iv  Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................................................................ 13 Brochure Supplement (Part 2B of Form ADV) .......................................................................... 15 Bankruptcy Petitions during the Past Ten Years .............................................................................................. 13 Principal Executive Officer – Alan N. Hoffman .................................................................................................. 15 Item 2 - Educational Background and Business Experience ....................................................................... 15 Item 3 - Disciplinary Information ........................................................................................................................... 15 Item 4 - Other Business Activities Engaged In ................................................................................................... 15 Item 5 - Additional Compensation .......................................................................................................................... 15 Item 6 - Supervision ..................................................................................................................................................... 15 v  Item 4: Advisory Business Firm Description Types of Advisory Services Hoffman, Alan N. Investment Management was founded in 1995. Alan N. Hoffman is a sole proprietor doing business as Hoffman, Alan N. Investment Management. Client Tailored Services and Client Imposed Restrictions ASSET MANAGEMENT Hoffman, Alan N. Investment Management offers discretionary asset management services to advisory Clients. Hoffman, Alan N. Investment Management will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. Hoffman, Alan N. Investment Management specializes in Large Cap Growth Equity Investments. The Client will authorize Hoffman, Alan N. Investment Management discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Wrap Fee Programs Agreements may not be assigned without written Client consent. Client Assets Under Management Hoffman, Alan N. Investment Management does not sponsor any wrap fee programs. Hoffman, Alan N. Investment Management has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: $183,357,629 $0 Date Calculated: December 31, 2025 Item 5: Fees and Compensation Method of Compensation and Fee Schedule ASSET MANAGEMENT Hoffman, Alan N. Investment Management offers discretionary direct asset management services to advisory Clients. Hoffman, Alan N. Investment Management charges an annual investment advisory fee based on the total assets under management of 1.5%. For example, a client with $500,000 under management would pay $7,500 on an annual basis. Each quarter the fee for this account will be calculated as follows: Account balance at quarter end X (1.5%/4) = Quarterly Fee. The annual fee may be negotiable based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar 1  amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). Fees are billed quarterly in arrears based on the amount of assets managed as of the close of business on the last business day of the previous quarter. Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. Clients may terminate advisory services with thirty (30) days written notice. For accounts opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. All unpaid earned fees will be due to Hoffman, Alan N. Investment Management. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. If Hoffman, Alan N. Investment Management is authorized or permitted to deduct fees directly from the account by the custodian: • Hoffman, Alan N. Investment Management will provide the Client with an invoice concurrent to instructing the custodian to deduct the fee stating the amount of the fee, the formula used to calculate the fee, the amount of assets under management the fee is based on and the time period covered by the fee; • Hoffman, Alan N. Investment Management will obtain written authorization signed by the Client allowing the fees to be deducted; and • The Client will receive quarterly statements directly from the custodian which Client Payment of Fees disclose the fees deducted. Investment management fees are billed quarterly in arrears, meaning that we invoice you after the billing period. Fees are usually deducted from a designated Client account to facilitate billing. The Client must consent in advance to direct debiting of their investment account. Hoffman, Alan N. Investment Management, in its sole discretion, may waive its minimum fee and/or charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, Additional Client Fees Charged negotiations with Clients, etc.). Custodians may charge transaction fees on purchases or sales of certain mutual funds, equities, and exchange-traded funds. These charges may include mutual fund transaction fees, postage and handling and miscellaneous fees. Prepayment of Client Fees For more details on the brokerage practices, see Item 12 of this brochure. Hoffman, Alan N. Investment Management does not require any prepayment of fees. 2  External Compensation for the Sale of Securities to Clients Hoffman, Alan N. Investment Management does not receive any external compensation for the sale of securities to Clients, nor do any of the investment advisor representatives of Hoffman, Alan N. Investment Management. Item 6: Performance-Based Fees and Side-by-Side Management Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. Hoffman, Alan N. Investment Management does not use a performance-based fee structure because of the conflict of interest. Performance based compensation may create an incentive for Hoffman, Alan N. Investment Management to recommend an investment that may carry a higher degree of risk to the Client. Item 7: Types of Clients Description Hoffman, Alan N. Investment Management generally provides investment advice to individuals and high net worth individuals. Account Minimums Client relationships vary in scope and length of service. Hoffman, Alan N. Investment Management requires a minimum of $100,000 to open an account. In certain instances, the minimum account size may be lowered or waived. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include fundamental analysis. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. The risk assumed is that the market will fail to reach expectations of perceived value. Investment Strategy The main sources of information include financial newspapers and magazines, annual reports, prospectuses, and filings with the Securities and Exchange Commission. The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. Hoffman, Alan N. Investment Management’s investment strategy is to invest in high quality Large Cap Growth Stocks. The Client may change these objectives at any time by providing written notice to Hoffman, Alan N. Investment Management. Each 3  Client executes a Client profile form or similar form that documents their objectives and their desired investment strategy. Security Specific Material Risks Other strategies may include long-term purchases. • Market Risk All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks and should discuss these risks with Hoffman, Alan N. Investment Management: • : The prices of securities held by mutual funds in which Clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to Interest-rate Risk tolerate potentially sharp declines in market value. • : Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less Inflation Risk attractive, causing their market values to decline. : When any type of inflation is present, a dollar today will buy more than • Currency Risk a dollar next year, because purchasing power is eroding at the rate of inflation. • Reinvestment Risk : Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Liquidity Risk : This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Management Risk: : Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Equity Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the Client’s portfolio may suffer. Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the Client’s overall portfolio. Small and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. lower trading volume, which may Smaller companies may also have a 4  • Fixed Income Risk: disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. • The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A nominal Investment Companies Risk: interest rate is the sum of a real interest rate and an expected inflation rate. • Foreign Securities Risk: When a Client invests in open end mutual funds or ETFs, the Client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, which may be duplicative. In addition, the Client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which Client invests. • Long-term purchases Funds in which Clients invest may invest in foreign securities. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less publicly available information, limited trading markets and greater volatility. To the extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies. • Trading risk : Long-term investments are those vehicles purchased with the intension of being held for more than one year. Typically, the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. • Mutual Fund risk: : Investing involves risk, including possible loss of principal. There is no assurance that the investment objective of any fund or investment will be achieved. Investing in a mutual fund may cause you to bear additional expenses based on your pro rata share of the mutual fund’s operating expenses, 5  • Exchange Traded Fund (ETF) risk: including the potential duplication of management fees. The risk of owning a mutual fund generally reflects the risks of owning the underlying securities the mutual fund holds. You may also incur brokerage costs when purchasing mutual funds. Investing in an ETF may cause you to bear additional expenses based on your pro rata share of the ETF’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF generally reflects the risks of owning the underlying securities the ETF holds. Other risks may include the ETF not tracking the index as designed and potential liquidity and shutdown risks. Item 9: Disciplinary Information Criminal or Civil Actions Administrative Enforcement Proceedings Hoffman, Alan N. Investment Management and its management have not been involved in any criminal or civil action. Self- Regulatory Organization Enforcement Proceedings Hoffman, Alan N. Investment Management and its management have not been involved in administrative enforcement proceedings. Hoffman, Alan N. Investment Management and its management have not been involved in legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of Hoffman, Alan N. Investment Management or the integrity of its management. Pursuant to Mass. Code Regs. 12.205(8)(d), Client can obtain the disciplinary history of Hoffman, Alan N. Investment Management or its representatives upon request of the Massachusetts Securities Division. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration Hoffman, Alan N. Investment Management is not registered as a broker-dealer and no affiliated representatives of Hoffman, Alan N. Investment Management are registered Futures or Commodity Registration representatives of a broker-dealer. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Neither Hoffman, Alan N. Investment Management nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Recommendations or Selections of Other Investment Advisors and Conflicts of Interest Alan N. Hoffman has no material relationships to disclose. Hoffman, Alan N. Investment Management does not select or recommend other investment advisors. 6  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description include employees and/or The affiliated persons (affiliated persons independent contractors) of Hoffman, Alan N. Investment Management have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of Hoffman, Alan N. Investment Management affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of Hoffman, Alan N. Investment Management. The Code reflects Hoffman, Alan N. Investment Management and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. Hoffman, Alan N. Investment Management’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other employee, officer or director of Hoffman, Alan N. Investment Management may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. Hoffman, Alan N. Investment Management’s Code is based on the guiding principle that the interests of the Client are our top priority. Hoffman, Alan N. Investment Management’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. Hoffman, Alan N. Investment Management will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflict of Interest Hoffman, Alan N. Investment Management and its affiliated persons do not recommend to Clients securities in which we have a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Hoffman, Alan N. Investment Management and its affiliated persons may buy or sell securities that are also held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable 7  securities transactions as well as provide Hoffman, Alan N. Investment Management with copies of their brokerage statements. The Chief Compliance Officer of Hoffman, Alan N. Investment Management is Alan N. Hoffman. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest Hoffman, Alan N. Investment Management does not maintain a firm proprietary trading account and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. However, affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. In order to mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable securities transactions as well as provide Hoffman, Alan N. Investment Management with copies of their brokerage statements. The Chief Compliance Officer of Hoffman, Alan N. Investment Management is Alan N. Hoffman. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions 3 2 registered broker-dealer and SIPC Hoffman, Alan N. Investment Management requires that Clients establish brokerage 1 accounts with the Schwab Advisor Services division of Charles Schwab & Co., Inc. ("Schwab"), a FINRA member, to maintain custody of Clients’ assets and to effect trades for their accounts. Hoffman, Alan N. Investment Management is independently owned and operated and not affiliated with Schwab. Hoffman, Alan N. Investment Management has evaluated Schwab and believes that it will provide our Clients with a blend of execution services, commission costs and professionalism that will assist our firm in meeting our fiduciary obligations to Clients. Schwab provides Hoffman, Alan N. Investment Management with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s Clients’ assets are maintained in accounts at Charles Schwab & Co. These services are not contingent upon our firm committing to Schwab any specific amount of business (assets in custody or 1 2 For information regarding Schwab, please refer to their website: https://www.schwab.com/. FINRA is the largest independent regulator for all securities firms doing business in the United States. For more information, please refer to FINRA’s website: http://www.finra.org/. 3 For information regarding SIPC, please refer to their website: http://www.sipc.org/. 8  trading commissions). Schwab’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. For our Client accounts maintained in its custody, Schwab 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 Schwab or that settle into Schwab accounts. Charles Schwab & Co. also makes available to Hoffman, Alan N. Investment Management other products and services that benefit Hoffman, Alan N. Investment Management but may not directly benefit our Clients’ accounts. Many of these products and services may be used to service all or some substantial number of our Client accounts, including accounts not maintained at Schwab. Schwab’s products and services that assist Hoffman, Alan N. Investment Management in managing and administering our Clients’ accounts include 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 our fees from Clients’ accounts; and assist with back-office functions, recordkeeping and Client reporting. Charles Schwab & Co. also offers other services intended to help us manage and further develop our business enterprise. These services may include: • • • compliance, legal and business consulting; publications and conferences on practice management and business succession; and access to employee benefits providers, human capital consultants and insurance providers. Schwab may make available, arrange and/or pay third-party vendors for the types of services rendered to Hoffman, Alan N. Investment Management. Charles Schwab & Co. may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to our firm. Charles Schwab & Co. may also provide other benefits such as educational events or occasional business entertainment of our personnel. In evaluating whether to recommend or require that Clients custody their assets at Schwab, we 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 we consider and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest. Hoffman, Alan N. Investment Management reserves the right to decline acceptance of any Client account for which the Client directs the use of a broker other than Schwab if we believe that this choice would hinder our fiduciary duty to the Client and/or our ability to service 9  • Directed Brokerage the account. In directing the use of Schwab (or any other broker), it should be understood that Hoffman, Alan N. Investment Management will not have authority to negotiate commissions or to necessarily obtain volume discounts, and best execution may not be achieved. In addition, a disparity in commission charges may exist between the commissions charged to the Client and those charged to other Clients (who may direct the use of another broker other than Schwab). Clients should note that, while Hoffman, Alan N. Investment Management has a reasonable belief that Schwab is able to obtain best execution and competitive prices, our firm will not independently seek best execution price capability through other brokers. Hoffman, Alan N. Investment Management does not allow directed brokerage • Best Execution accounts. • Soft Dollar Arrangements Investment advisors who manage or supervise Client portfolios have a fiduciary obligation of best execution. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is affected, the ability to effect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. Hoffman, Alan N. Investment Management does not receive any portion of the trading fees. The Securities and Exchange Commission defines soft dollar practices as arrangement under which products or services other than execution services are obtained by Hoffman, Alan N. Investment Management from or through a broker- dealer in exchange for directing Client transactions to the broker-dealer. As permitted by Section 28(e) of the Securities Exchange Act of 1934, Hoffman, Alan N. Investment Management receives economic benefits as a result of commissions generated from securities transactions by the broker-dealer from the accounts of Hoffman, Alan N. Investment Management. These benefits include both proprietary research from the broker and other research written by third parties. A conflict of interest exists when Hoffman, Alan N. Investment Management receives soft dollars. This conflict is mitigated by the fact that Hoffman, Alan N. Investment Management has a fiduciary responsibility to act in the best interest of its Clients and the services received are beneficial to all Clients. Hoffman, Alan N. Investment Management utilizes the services of custodial broker dealers. Economic benefits are received by Hoffman, Alan N. Investment Management which would not be received if Hoffman, Alan N. Investment Management did not give investment advice to Clients. These benefits include: A dedicated trading desk, a dedicated service group and an account services manager dedicated to Hoffman, Alan N. Investment Management's accounts, ability to conduct "block" Client trades, 10  Aggregating Securities Transactions for Client Accounts electronic download of trades, balances and positions, duplicate and batched Client statements, and the ability to have advisory fees directly deducted from Client accounts. Hoffman, Alan N. Investment Management is authorized in its discretion to aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of Hoffman, Alan N. Investment Management. All Clients participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rated basis. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Review of Client Accounts on Non-Periodic Basis Account reviews are performed quarterly by the Chief Compliance Officer of Hoffman, Alan N. Investment Management. Account reviews are performed more frequently when market conditions dictate. Reviews of Client accounts include, but are not limited to, a review of Client documented risk tolerance, adherence to account objectives, investment time horizon, and suitability criteria, reviewing target bans of each asset class to identify if there is an opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities. Content of Client Provided Reports and Frequency Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, and changes in a Client's own situation. Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by Hoffman, Alan N. Investment Management’s custodian. Client receives confirmations of each transaction in account from Custodian and an additional statement during any month in which a transaction occurs. Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest As disclosed under Item 12 above, Hoffman, Alan N. Investment Management receives an economic benefit from Schwab in the form of the support products and services it makes available to Hoffman, Alan N. Investment Management and other independent investment advisors that have their Clients maintain accounts at Schwab. These products and services, how they benefit Hoffman, Alan N. Investment Management, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability to Hoffman, Alan N. Investment Management of Schwab’s products and services is not based on Hoffman, Alan N. Investment Management giving particular investment advice, such as buying particular securities for our Clients. 11  Advisory Firm Payments for Client Referrals Hoffman, Alan N. Investment Management does not compensate for Client referrals. Item 15: Custody Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at their address of record at least quarterly. Clients are urged to compare the account statements received directly from their custodians to any documentation or reports prepared by Hoffman, Alan N. Investment Management. Hoffman, Alan N. Investment Management is deemed to have limited custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of Hoffman, Alan N. Investment Management. Item 16: Investment Discretion Discretionary Authority for Trading Hoffman, Alan N. Investment Management requires discretionary authority to manage securities accounts on behalf of Clients. Hoffman, Alan N. Investment Management has the authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The client will authorize Hoffman, Alan N. Investment Management discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. Hoffman, Alan N. Investment Management allows Client’s to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. Such restrictions could include only allowing purchases of socially conscious investments. These restrictions must be provided to Hoffman, Alan N. Investment Management in writing. Hoffman, Alan N. Investment Management does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17: Voting Client Securities Proxy Votes Hoffman, Alan N. Investment Management does not vote proxies on securities. Clients are expected to vote their own proxies. The Client will receive their proxies directly from the custodian of their account or from a transfer agent. When assistance on voting proxies is requested, Hoffman, Alan N. Investment Management will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. 12  Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided because Hoffman, Alan N. Investment Management does not serve as a custodian for Client funds or securities and Hoffman, Alan N. Investment Management does not require prepayment of fees of more than $1,200 per Client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients Bankruptcy Petitions during the Past Ten Years Hoffman, Alan N. Investment Management has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. Hoffman, Alan N. Investment Management has not had any bankruptcy petitions in the last ten years. 13  S U P E R V I S E D P E R S O N B R O C H U R E Item 1 Cover Page F O R M A D V P A R T 2 B Alan N. Hoffman Hoffman, Alan N. Investment Management Office Address: 40 William St Unit 604 Wellesley, MA 02481 Tel: 617-308-5087 alanhoffman@icloud.com Website: www.anhinvest.com J A N U A R Y 2 1 , 2 0 2 6 This brochure supplement provides information about Alan N. Hoffman and supplements the Hoffman, Alan N. Investment Management brochure. You should have received a copy of that brochure. Please contact Alan N. Hoffman if you did not receive the brochure or if you have any questions about the contents of this supplement. Additional information about Alan N. Hoffman (CRD #2616886) is available on the SEC’s website at www.adviserinfo.sec.gov. 14  Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Principal Executive Officer – Alan N. Hoffman • Item 2 - Educational Background and Business Experience Year of birth: 1954 • Educational Background: • • University of Massachusetts, Amherst; Bachelor of Arts – Political Science; 1976 Indiana University, Bloomington; Master of Business Administration – Finance; 1978 Indiana University; Doctor of Business Administration – Strategic Management; 1982 • Business Experience: • • • Item 3 - Disciplinary Information None to report. Hoffman, Alan N. Investment Management.; Owner/Investment Advisor Representative; 07/1995-Present Pearson; Textbook Author; 08/2011-Present Bentley University; Tenured Professor; 09/1988-12/2020 Rotterdam School of Management, Erasmus University; Visiting Professor; 01/2010- 05/2012 Criminal or Civil Action: Administrative Proceeding: Self-Regulatory Proceeding: Item 4 - Other Business Activities Engaged In None to report. None to report. Item 5 - Additional Compensation Alan N. Hoffman receives compensation as a textbook author. This practice does not represent a conflict of interest. He has no other business activities to disclose. Item 6 - Supervision Alan N. Hoffman does not receive any additional compensation for advisory services and he does not receive any performance based fees. Since Alan N. Hoffman is the sole owner and investment adviser representative of Hoffman, Alan N. Investment Management he is solely responsible for all supervision and formulation and monitoring of investment advice offered to Clients. He will adhere to the policies and procedures as described in the firm’s Compliance Manual. He can be reached at alanhoffman@icloud.com or 617-308-5087. 15