Overview
- Headquarters
- Seattle, WA
- Average Client Assets
- $5.2 million
- Minimum Account Size
- $1,000,000
- SEC CRD Number
- 300140
Fee Structure
Primary Fee Schedule (HOHIMER WEALTH MANAGEMENT FORM ADV 2A BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $2,000,000 | 1.50% |
| $2,000,001 | $5,000,000 | 1.00% |
| $5,000,001 | $10,000,000 | 0.75% |
| $10,000,001 | $25,000,000 | 0.60% |
| $25,000,001 | $50,000,000 | 0.50% |
| $50,000,001 | $100,000,000 | 0.40% |
| $100,000,001 | and above | 0.35% |
Minimum Annual Fee: $8,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $15,000 | 1.50% |
| $5 million | $60,000 | 1.20% |
| $10 million | $97,500 | 0.98% |
| $50 million | $312,500 | 0.62% |
| $100 million | $512,500 | 0.51% |
Clients
- HNW Share of Firm Assets
- 74.13%
- Total Client Accounts
- 1,554
- Discretionary Accounts
- 1,411
- Non-Discretionary Accounts
- 143
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Pooled Investment Vehicles, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection
Regulatory Filings
Additional Brochure: HOHIMER WEALTH MANAGEMENT FORM ADV 2A BROCHURE (2026-03-31)
View Document Text
Form ADV Part 2A
Firm Brochure
March 16, 2026
One Union Square • 600 University Street, Suite 2401
Seattle, WA 98101
Phone: 206-709-5950
www.HohimerWealthManagement.com
This Brochure provides information about the qualifications and business practices of Hohimer Wealth Management, LLC
(“HWM”). If you have any questions about the contents of this Brochure, please contact us at
compliance@hohimerwealthmanagement.com.
The information in this Brochure has not been approved or verified by the United States of America Securities and Exchange
Commission (“SEC”) or by any state securities authority.
HWM is a registered investment adviser. The 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 HWM also 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 HWM is 300140.
Hohimer Wealth Management LLC • Form ADV Part 2A Brochure • March 2026
Page 1
Item 2 – Material Changes
This Item of the Brochure discusses only specific material changes that are made to the Brochure and provides clients with a
summary of such changes. Since our last annual updating amendment, the following material changes have been made to
New Investment Strategy (“Hedged Growth”):
our business and this Brochure:
HWM now offers a specialized “Hedged Growth” investment strategy. This
approach utilizes both fundamental and technical analysis to deploy conservative options strategies—specifically covered
calls and put hedges—aimed at generating income, mitigating downside risk, and maximizing tax efficiency in taxable
Private Fund Management:
accounts. (See Item 8 for a full description and associated risks).
HWM now serves as the investment manager for two (2) private real estate funds. This
Launch of Tax & Accounting Solutions:
introduces new fee structures and conflicts of interest, which are detailed in Items 4 and 10.
HWM has expanded its service offerings to include specialized Tax Planning &
Accounting Solutions. These services are distinct from our core wealth management offering and require a separate written
agreement. To maintain strict privacy and regulatory firewalls, client financial data is not shared between the wealth
management and tax units unless the client explicitly executes an “Authorization for Unified Services and Information
Sharing” consent form.
At any time, you may view the current Brochure on-line at SEC’s Investment Adviser Public Disclosure website at:
www.adviserinfo.sec.gov. You may also request a copy of this Brochure at any time, by contacting
dstlouis@hohimerwealthmanagement.com.
Hohimer Wealth Management LLC • Form ADV Part 2A Brochure • March 2026
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Item 3 – Table of Contents
Item 1 – Cover Page
Item 2 – Material Changes
Item 3 – Table of Contents
Item 4 – Advisory Business
Item 5 – Fees and Compensation
Item 6 – Performance-Based Fees and Side-By-Side Management
Item 7 – Types of Clients
Item 8 – Methods of Analysis, Investment Strategies
Item 9 – Disciplinary Information
Item 10 – Other Financial Industry Activities and Affiliations
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading
Item 12 – Brokerage Practices
Item 13 – Review of Accounts
Item 14 – Client Referrals and Other Compensation
Item 15 – Custody
Item 16 – Investment Discretion
Item 17 – Voting Client Securities
Item 18 – Financial Information
Hohimer Wealth Management LLC • Form ADV Part 2A Brochure • March 2026
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Item 4 – Advisory Business
HWM is an investment adviser registered with the Securities and Exchange Commission. Registration does not imply a
certain level of skill or training. HWM is solely owned by David Hohimer and has been providing advisory services since
2019.
HWM offers a variety of advisory services, which include investment and wealth management, financial planning, and
consulting services. Prior to HWM rendering any of the foregoing services, clients are required to enter into one or more
written agreements with HWM setting forth the relevant terms and conditions of the advisory relationship (the “Advisory
Agreement”). HWM manages investment portfolios for individuals, high net worth individuals, pensions, trusts,
corporations, and private investment funds (including two real estate funds). HWM will work with a client to determine the
client’s investment objectives and investor risk profile. These investment objectives may be set forth in a written Investment
Policy Statement (“IPS”) that describes an asset allocation that conforms to a client’s risk tolerance level and expected rate
of return requirements. Investment and portfolio allocation software is used to evaluate alternative portfolio designs. HWM
evaluates clients’ existing investments with respect to their IPS and works with new clients to develop a plan to transition
from a client’s existing portfolio to the portfolio recommended by HWM. HWM then continuously monitors clients’ portfolio
holdings and holds regular review meetings with clients regarding their accounts, as necessary.
HWM will utilize the financial information provided by the client to analyze and develop strategies and solutions to assist
the client in meeting their financial goals. HWM will allocate a client’s assets among various investments taking into
consideration the client’s unique ability, need, and willingness to take risk.
Investment and Wealth Management Services
HWM manages portfolios on both a discretionary and non-discretionary basis. HWM may also provide its clients with a
broad range of services, as described in more detail below. HWM advises its clients by delivering tailored wealth
management services and solutions. These services are based on a comprehensive understanding of each client’s current
situation, past experiences, and future goals. With this acquired knowledge HWM will create, analyze, strategize, and
implement goal-oriented investment solutions. These solutions become our client’s investment policy. This policy and our
matched strategies are designed to be risk appropriate, cost effective and tax efficient.
HWM provides clients with wealth management services which generally include a broad range of comprehensive financial
planning and consulting services, as well as discretionary and/or, in very limited circumstances, non-discretionary
management of investment portfolios.
HWM primarily allocates client assets among individual equity and debt securities, exchange-traded funds (“ETFs”), and
institutional mutual funds in accordance with the client’s stated investment objective and risk/volatility parameter. HWM
may also occasionally recommend clients allocate certain portion of their assets to independent investment managers
(“Independent Managers”). Where appropriate, HWM may also provide advice about many types of legacy positions or other
investments held in client portfolios. Clients may engage HWM to manage and/or advise on certain investment products
that are not maintained at their primary custodian, such as variable life insurance and annuity contracts (to the extent
permissible without an insurance license) and assets held in employer sponsored retirement plans and qualified tuition
plans (i.e., 529 plans). In these situations, HWM will direct or make recommendations on a non-discretionary basis for the
allocation of client assets among the various investment options available with the product. These assets are generally
maintained at the underwriting insurance company or custodian for the plan trustee or administrator and clients retain
responsibility for effecting trades in these accounts.
HWM tailors its advisory services to meet the needs of its individual clients and seeks to manage client portfolios in a
manner consistent with the client’s investment objective and risk tolerance parameter. HWM consults with clients on an
initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors
relevant to the management of their portfolios. Clients are advised to promptly notify HWM if there are changes in their
financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose
reasonable restrictions or mandates on the management of their accounts if HWM determines, in its sole discretion, the
conditions would not materially impact the performance of a management strategy or prove overly burdensome to the
Firm’s management efforts.
To the extent a client decides to invest with an Independent Manager or in a particular fund, those managers and funds will
have their own investment practices. Those investment practices are described in each managers’ Form ADV or fund’s
prospectus, or in its offering or other disclosure documents. In addition, selected money managers or funds typically have
discretion to determine the type and amount of securities to be purchased or sold for the client for that portion of the
client’s assets managed by the money manager or fund.
Hohimer Wealth Management LLC • Form ADV Part 2A Brochure • March 2026
Page 4
In certain cases, HWM will recommend that a portion of a client’s assets be invested in certain private funds. Such funds are
described as hedge funds, real estate funds, private equity funds, venture capital funds and other types of private pooled
investment vehicles (collectively “Private Funds”).
While HWM strives for fair and balanced allocation of private fund investment opportunities, individual recommendations
depend on several factors, including investment experience, investment sophistication, risk tolerance, financial goals, and
available assets. HWM’s goal is to allocate in a fair and balanced manner, however, not all eligible clients will receive every
private fund recommendation due to these varying considerations.
Before investing in a Private Fund, HWM requires that clients carefully review the offering documents to understand its
risks and any potential conflicts of interest. (See Item 12 for details on allocating Private Fund investments.)
Certain Private Funds, mutual funds, and ETFs in HWM’s portfolio involve advanced investment strategies like leverage and
derivatives. Leverage, essentially borrowing to invest, can amplify both gains and losses, as seen when a private fund
leverages a line of credit for acquisition, or a hedge fund uses shorted stock proceeds for further investments. Similarly,
derivatives, contracts tied to the value of another asset, can be highly sensitive to market fluctuations and potentially lead to
losses exceeding the initial investment. While these strategies can potentially enhance returns, their use and the associated
costs can also lead to losses. Hedging, on the other hand, involves offsetting potential losses with other investments, like
shorting a security to protect a long position. Carefully consider these and other factors before investing. For more
information on HWM’s analysis methods and associated risks, please refer to Item 8.
Independent Managers
As mentioned above, HWM may select certain Independent Managers to actively manage a portion of its clients’ assets.
Pursuant to the terms of the Advisory Agreement, HWM shall have the discretion to appoint and terminate these third-party
advisers. The specific terms and conditions under which a client engages an Independent Manager may also be set forth in a
separate written agreement with the designated Independent Manager. In addition to this brochure, clients may also receive
the written disclosure documents of the respective Independent Managers engaged to manage their assets. HWM evaluates
a variety of information about Independent Managers, which may include the Independent Managers’ public disclosure
documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are
reputable. To the extent possible, HWM seeks to assess the Independent Managers’ investment strategies, past performance,
and risk results in relation to its clients’ individual portfolio allocations and risk exposure. HWM also takes into
consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing, and
research capabilities, among other factors.
HWM continues to provide services relative to the discretionary or non-discretionary selection of the Independent
Managers. On an ongoing basis, HWM monitors the performance of those accounts being managed by Independent
Managers. HWM seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’
investment objectives and overall best interests.
Financial Planning and Consulting Services
HWM starts with an extensive review of a client’s family situation which includes assets and liabilities as well as estate, tax,
and insurance needs. The Firm then employs a risk tolerance and risk capacity-focused considerations to get a detailed cash
flow analysis and proposed asset allocation. Together, this information is analyzed to develop a proposed financial plan,
which is designed to be dynamic in nature, ever-evolving due to life changes resulting from changes in cash flow needs, risk
tolerance, time horizon, or investment objectives.
HWM’s financial planning and consulting services may include any or all of the following functions: Business Planning,
Liability Management, Cash Flow Forecasting, Risk Management, Trust and Estate Planning, Charitable Planning, Financial
Planning, Distribution Planning, Investment Consulting, Tax Planning, Insurance Planning, Family Wealth Stewardship, and
Retirement Plan Consulting.
Tax & Accounting Solutions
In addition to our core wealth management and financial planning services, HWM offers specialized Tax & Accounting
Solutions. Please note that these tax services are not automatically included with our standard advisory services. Clients
wishing to utilize HWM for tax planning, preparation, or accounting must enter a separate, specific written agreement for
those services.
Furthermore, while HWM offers both wealth management and tax services, the data and records for these two units are kept
strictly segregated to protect client privacy. To facilitate the sharing of financial documents (such as K-1s, 1099s, and
Hohimer Wealth Management LLC • Form ADV Part 2A Brochure • March 2026
Page 5
portfolio data) between the wealth management arm and the tax and accounting arm, clients must explicitly grant
permission by signing an “Authorization for Unified Services and Information Sharing” consent form.
While each of these services is available on a stand-alone basis, certain of them may also be rendered in conjunction with
investment portfolio management services, as part of a comprehensive wealth management engagement (described in more
detail below). In performing these services, HWM is not required to verify any information received from the client or from
the client’s other professionals (e.g., attorneys, accountants, etc.), and is expressly authorized to rely on such information.
HWM may recommend clients engage the firm for additional related services, or we may recommend other professionals to
implement recommendations made by HWM. Such additional services by HWM or another professional will be provided for
additional compensation, commensurate with the nature, extent, complexity, and other characteristics of such services.
Clients are advised that a conflict of interest exists because the firm will have an incentive to recommend such additional
services based on the compensation to be received, rather than solely based on the client’s needs, and in some cases, based
on the prospect of cross-referrals of advisory clients from the other professional or his or her firm.
HWM also provides advice in the form of financial consultations. These services, charged on either an hourly or fixed fee
basis, consist of consultations based on specific investment and financial concerns of the client. Consulting services may
include, for example, assistance with establishing and implementing a retirement plan, preparation or review of an
investment policy statement, the compilation of reports on various investment accounts, and asset allocation
recommendations. The scope and depth of the consultation varies depending on the client’s particular circumstances and
needs. HWM provides financial planning and consulting services to non-advisory clients for a fixed fee or hourly fee.
Clients are under no obligation to act upon any recommendations made by HWM under a financial planning or consulting
engagement or to engage the services of a third-party professional. Clients retain the absolute right to decide whether to act
on such recommendations, and if they choose to act on such recommendations, whether to engage the Firm or such
professional for such services or to engage another investment adviser or professional of their choosing, which may charge
less (or more) for such services. Should a client choose to implement the recommendations contained in the plan, HWM
suggests the client work closely with his/her attorney, accountant and/or insurance agent.
At HWM, we integrate your family’s values into the family wealth stewardship process, with strategic wealth management,
crafting enduring legacies that transcend generations.
Implementation of financial plan recommendations is entirely at the client’s discretion. Financial planning
recommendations are of a generic nature and are not limited to any specific product or service offered by a broker dealer or
Wrap Fee Program
insurance company.
HWM also offers portfolio management services through a wrap fee program. A wrap fee program is an investment program
wherein the investor pays one stated fee that includes management fees, transaction costs, custody, fund expenses, and any
other administrative fees. Please refer to our Wrap Fee Brochure for more information on our Comprehensive Wrap Fee
Program. A wrap fee program may not be the lowest cost option if you would like to restrict your investments to open-end
Pension and Other Retirement Plans
mutual funds or other long-term investment products.
In the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), HWM
provides advisory services to pension plans and retirement plan clients. These include advisory services to company
retirement plans (each a “Plan”) and the Plan’s sponsor (the “Plan Sponsor”). HWM provides discretionary advisory services
as a 3(38) or non-discretionary advisory services as a 3(21) Fiduciary in support of the Plan Sponsor. HWM will provide the
following plan fiduciary services pursuant to the terms of the Advisory Agreement with each Plan Sponsor:
•
•
•
•
•
•
•
•
Plan Design Assistance
Vendor Analysis
Plan Participant Enrollment
Investment Policy Statement (“IPS”)
Investment Monitoring/Recommendation
Plan Effectiveness Monitoring
ERISA 404(c) Assistance
Benchmarking Services
In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of HWM’s fiduciary
status, the specific services to be rendered and all direct and indirect compensation HWM reasonably expects under the
Hohimer Wealth Management LLC • Form ADV Part 2A Brochure • March 2026
Page 6
engagement. HWM also provides the following non-advisory services to the Plan and the Plan Participants, pursuant to the
terms of the Advisory Agreement with each Plan Sponsor:
•
•
•
•
Investment Education
Plan Sponsor Fiduciary Education
Periodic on-site advisor visits with staff for account updates and reviews
Periodic Plan Participant group education opportunities
HWM uses a third-party platform to facilitate management of some held away assets, such as defined contribution plan
participant accounts, with discretion. We are not affiliated with the platform in any way and receive no compensation from
them for using their platform. A link will be provided to the client allowing them to connect an account(s) to the platform.
Once the client’s account(s) is connected to the platform, HWM will review the current account allocations. When deemed
necessary, HWM will rebalance the account considering client investment goals and risk tolerance, and any change in
allocations will consider current economic and market trends. Client account(s) will be reviewed at least annually, and
allocation changes will be made as deemed necessary.
In recommending that any client roll over retirement plan assets to our management, we have a conflict of interest. Before
making any such recommendation, we review the client’s existing investment options, fees, and expenses in the context of
their overall investment objectives. We only make the recommendation once we have determined that doing so is in the
Margin Accounts
client’s best interest.
Using margin in your account, while increasing your total assets and thus our advisory fee, presents a potential conflict of
interest for our firm. Our loyalty is to you, the client, and we recognize that margin carries significant risks and isn’t suitable
for all investors. We always recommend prudent use of margin, if at all. Buying securities on margin incurs additional costs
Legal, Accounting or Tax Advice
and risks, so weigh these carefully before proceeding. See Item 8 for details.
HWM does not provide any legal advice. Client should seek the counsel of a qualified accountant and/or attorney when
necessary. As a courtesy, HWM can offer Tax advice/services, with a registered Tax Enrolled Agent on staff. HWM may also
assist clients with tax harvesting, and we will work with a client’s tax specialist to answer any questions related to the
client’s portfolio account.
As of December 31, 2024, HWM has $921,675,640 discretionary assets under management and $72,021,035 non-
discretionary assets under management.
Hohimer Wealth Management LLC • Form ADV Part 2A Brochure • March 2026
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Item 5 – Fees and Compensation
HWM offers investment and wealth management services for an annual fee based on the amount of assets under the firm’s
management. The specific manner in which fees are charged by HWM is established in a client’s Advisory Agreement. HWM
will generally bill its fees in advance each calendar quarter based on the client’s previous quarter end value. Clients may
elect to be billed directly for fees or to authorize HWM to directly debit fees from the client’s portfolio accounts. Accounts
initiated or terminated during a calendar quarter will be charged a prorated fee. Upon termination of any account, any
prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable.
For investment and wealth management services HWM provides with respect to certain client holdings (e.g., held-away
assets, 529 plans, etc.), HWM may negotiate a fee rate that differs from the range set forth below. HWM, may, in its sole
discretion, negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity,
anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-
existing/legacy client relationship, account retention and pro bono activities. Clients should note that similar advisory
services may be available from other registered investment advisers for similar or lower fees.
HWM’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 investments and other
third parties such as fees charged by independent managers, custodial fees, deferred sales charges, odd-lot differentials,
transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s
prospectus. Such charges, fees and commissions are exclusive of and in addition to HWM’s fee, and HWM shall not receive
any portion of these commissions, fees, and costs. Clients with margin accounts are charged fees based on the full value of
their assets, including margin debt. This means that investments purchased on margin will increase the total fee amount.
HWM’s graduated fee schedule for investment management is as follows:
Assets Under Management
Maximum Annual Fee
First $2,000,000
1.50%
$2,000,000.01 – $5,000,000
1.00%
$5,000,000.01 – $10,000,000
0.75%
$10,000,000.01 – $25,000,000
0.60%
$25,000,000.01 – $50,000,000
0.50%
$50,000,000.01 – $100,000,000
0.40%
Over $100,000,000
0.35%
This fee schedule may be based on cumulative household assets under management. However, certain ERISA rules prevent
householding corporate plans with personal assets for fee reduction.
HWM generally imposes a minimum annual fee of $8,000, billed quarterly, per household for investment and wealth
management services. Existing clients may be grandfathered at the current fee rate reflected in the investment Advisory
Agreement. You should refer to your Advisory Agreement for your specific fee rate(s).
Clients engaging in Private Fund investments must be aware of the various fee structures involved. These may include
management fees, performance-based fees, and other associated expenses, all of which are outlined in the relevant offering
documents. A thorough review of these documents is paramount for comprehensive understanding of all fund-related costs.
Separate Financial Planning and Consulting Fee
Fees for financial planning services and consulting services are billed on a flat/project rate or hourly rate. The hourly fee
rate ranges between $150–$500 depending on the complexity of the services to be provided. HWM will request a retainer to
begin services and final payment is due after services are rendered. The maximum fee charged for financial planning
services is $50,000. In the event your financial planning or consulting agreement is terminated, and the fee is based on a flat
or project rate, the fee will be prorated based on the services provided through the date of termination.
HWM considers numerous factors when determining fees, including, without limitation:
Hohimer Wealth Management LLC • Form ADV Part 2A Brochure • March 2026
Page 8
•
•
•
•
•
The anticipated amount of time that will be spent completing the financial plan or consulting service and other
related advice;
The complexity of the client’s needs, issues and/or goals;
The extensiveness of the personal financial data needed to complete the financial plan;
The client’s net worth or value of investment accounts and/or other assets that are the subject of the financial plan
or consulting services; and/or
Special circumstances, such as life changes, marital status, special income needs, or needs related to a personal
business.
Other Types of Compensation We Receive
HWM is under common control with Risk & Liability Consultants LLC (“R&LC”) and LendinCo LLC (“LendinCo”), which
provides commercial loan brokerage services, licensed mortgage brokerage services and offers insurance products through
licensed agents and insurance agencies. Certain Supervised Persons of HWM are affiliated with R&LC and LendinCo and are
licensed insurance agents and loan officers, therefore may refer clients of HWM to R&LC and LendinCo, for which they and
HWM receive additional compensation in the form of transaction fees or commissions. The receipt of such compensation
presents a conflict of interest and gives the Firm and Supervised Persons of the Firm an incentive to recommend insurance
products and Lending services offered by R&LC and LendinCo.
HWM addresses these conflicts of interest by upholding its fiduciary duty to provide investment advice that is in your best
interest and disclosing these conflicts to you before or at the time you enter into an investment advisory contract with our
Firm. You have the option to purchase insurance or obtain lending services through individuals and entities that are not
affiliated with HWM.
Hohimer Wealth Management LLC • Form ADV Part 2A Brochure • March 2026
Page 9
Item 6 – Performance-Based Fees and Side-By-Side Management
HWM does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the
assets of a client) directly to clients for its standard advisory management.
However, HWM may charge performance-based fees to any private fund of which HWM is the advisor. These fees are based
on the Fund’s performance (capital gains or appreciation). Each Fund’s offering documents detail how these fees are
calculated, and they’re separate from HWM’s fees, and explains those conflicts.
Specifically, private funds may charge a performance fee of net profits above a (Hurdle Rate) benchmark. This fee is subject
to a (High-Water Mark) provision. Private fund investments are typically offered to accredited investors and/or qualified
purchasers, as defined by applicable securities laws. A potential conflict of interest arises as performance-based fees can
incentivize the fund manager to take on greater risks to achieve higher returns. Private fund investments are speculative
and involve a high degree of risk.
Please note that HWM doesn’t receive any portion of any Private Fund fees that are not managed by HWM.
Item 7 – Types of Clients
HWM provides portfolio management services to individuals, high net worth individuals, pension and profit-sharing plans,
trusts, estates, family entities, charitable institutions, foundations, corporations, and other business entities.
HWM generally requires a minimum account of $1,000,000 to open a portfolio. The firm, in its sole discretion, may accept
clients with smaller portfolios based upon each client’s particular circumstances as it deems appropriate. HWM may
aggregate the portfolios of family/household members to meet the minimum portfolio size.
Additionally, certain Independent Managers may impose more restrictive account requirements and varying billing
practices than HWM. In such instances, HWM may alter its corresponding account requirements and/or billing practices to
accommodate those of the Independent Managers.
Hohimer Wealth Management LLC • Form ADV Part 2A Brochure • March 2026
Page 10
Item 8 – Methods of Analysis, Investment Strategies
HWM will carefully construct a tax-efficient and cost-effective asset allocation strategy based on a client’s unique cash flow
needs, stated return and risk profile. Security selection is based on fundamental, quantitative, technical, and qualitative
factors. Portfolio holdings are constantly monitored and adjusted as market conditions and our clients’ circumstances
dictate. Clients may hold or retain other types of assets as well, and HWM may offer advice regarding those various assets as
part of its services.
Advice regarding such assets will generally not involve asset management services but may help to assist the client more
generally.
HWM predominantly allocates client assets to a combination of active and passive strategies, utilizing combinations of
publicly traded securities such as stocks, bonds, ETFs, mutual funds, customized structured notes, and alternative
investments. Nevertheless, individual client circumstances may dictate the use of other types of securities, actively managed
portfolios, or alternative investments, such as private funds and hedge funds. HWM works closely with clients to review the
suitability of these investments and any necessary allocation changes.
“Hedged Growth” Strategy
HWM offers a specialized investment strategy known as “Hedged Growth.” This strategy seeks to provide investors with
capital appreciation while systematically generating income and mitigating downside market risk through the conservative
use of options.
Fundamental Analysis for Equity Selection:
•
The Hedged Growth strategy relies on a dual-method analysis approach:
Utilizing fundamental analysis to select the underlying individual
• Technical Analysis for Options Deployment:
stocks for the portfolio. This involves evaluating a company’s financial health, earnings history, management team,
competitive advantages, and overall macroeconomic environment to identify high-quality equities.
Once an underlying equity position is established, technical analysis
becomes paramount. Analyzing price trends, market momentum, and historical volatility to determine the optimal
use of options, specifically guiding the selection of appropriate strike prices and contract durations.
Options Strategies Utilized
1. Covered Calls:
The Hedged Growth strategy relies exclusively on two conservative options strategies:
We sell (write) call options against shares of stock already held in the portfolio. This strategy
2. Put Hedges:
generates premium income, which can enhance overall returns and provide a small buffer against price declines in
the underlying stock.
We purchase put options on individual holdings or broad market indices to serve as portfolio
insurance. This strategy establishes a “floor” to protect the portfolio against significant downside declines.
Tax-Efficient Implementation
In taxable accounts, the Hedged Growth strategy is actively managed for tax efficiency. Particularly toward the end of the
calendar year, the deployment of covered calls and put hedges may be utilized strategically to manage realized capital gains
and losses, aiming to optimize the client’s after-tax return.
Risk of Loss
Investing in securities involves the risk of loss that clients should be prepared to bear. All investments present the risk of
loss of principal. In addition to general market risks, the Hedged Growth strategy and the use of options involve specific,
Options Risk:
material risks:
Options are complex financial instruments and are not suitable for all investors. The use of options can
Covered Call Risk (Capped Upside):
introduce different risk dynamics to a portfolio compared to simply holding the underlying stock.
By writing a covered call, the client receives premium income but forfeits the
opportunity to profit from any price appreciation of the underlying stock above the option’s strike price. If the stock price
Put Option Risk (Loss of Premium):
surges rapidly, the portfolio will underperform compared to simply holding the stock outright.
Purchasing put hedges requires paying a premium. If the underlying stock or market
index does not decline below the strike price by the expiration date, the put option will expire worthless, resulting in a total
loss of the premium paid. This constant “insurance cost” can create a drag on overall portfolio performance during extended
bull markets.
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Technical Analysis Risk:
The strategy relies heavily on technical analysis to set strike prices and durations. Technical
analysis relies on historical price movements and market trends, which may not accurately predict future market behavior.
Tax Risks:
Misjudging technical indicators can lead to options expiring worthless or being called away at sub-optimal prices.
While HWM attempts to manage the Hedged Growth strategy in a tax-efficient manner, the trading of options can
trigger complex tax rules (such as the straddle rules or constructive sales), which may affect the character and timing of
recognized gains and losses.
Equity Securities
In general, prices of equity securities (common, convertible preferred stocks and other securities whose values are tied to
the price of stocks, such as rights, warrants and convertible debt securities) are more volatile than those of fixed-income
securities. The prices of equity securities could decline in value if the issuer’s financial condition declines or in response to
overall market and economic conditions. Investments in smaller companies and mid-size companies may involve greater
risk and price volatility than investments in larger, more mature companies.
Fixed-Income Securities
The return and principal value of bonds fluctuate with changes in market conditions. Fixed-income securities are subject to
interest rate risk and credit quality risk. The market value of fixed-income securities generally declines when interest rates
rise, and an issuer of fixed-income securities could default on its payment obligations. Changes in interest rates generally
have a greater effect on bonds with longer maturities than on those with shorter maturities. If bonds are not held to
maturity, they may be worth more or less than their original value. Credit risk refers to the possibility that the issuer of a
bond will not be able to make principal and/or interest payments. High yield bonds, also known as “junk bonds,” carry a
higher risk of loss of principal and income than higher rated investment grade bonds.
Structured notes are not traded on public exchanges like stocks and bonds, making them less liquid than some other
investments. This means it might be difficult to sell them quickly without taking a loss, especially if market conditions are
unfavorable. Structured notes come with several drawbacks. They include credit risk, a lack of liquidity, inaccurate and
expensive pricing, call risk, unfavorable taxation, forgoing dividends, and, potentially, caps limiting gains and principal
protection.
While some structured notes offer the potential for higher returns than traditional fixed-income investments, they often
come with more significant risks. Additionally, fees associated with the note can eat into your returns. You can find
additional information regarding these risks in the fund’s prospectus.
Mutual Funds
Mutual funds may invest in different types of securities, such as value or growth stocks, real estate investment trusts,
corporate bonds, or U.S. government bonds. There are risks associated with each asset class.
An investment in a money market fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any
other governmental agency. Although money market funds seek to preserve the value of your investment at $1.00 per share,
it is possible to lose money by investing in the fund. Redemption is at the current net asset value, which may be more or less
than the original cost. Aggressive growth funds are most suitable for investors willing to accept price per share volatility
since many companies that demonstrate high growth potential can also be high risk.
Income from tax-free mutual funds may be subject to local, state and/or the alternative minimum tax.
Because each mutual fund owns different types of investments, performance will be affected by a variety of factors. The
value of your investment in a mutual fund will vary from day to day as the values of the underlying investments in a fund
vary. Such variations generally reflect changes in interest rates, market conditions and other company and economic news.
These risks may become magnified depending on how much a fund invests or uses certain strategies. A fund’s principal
market segment(s), such as large-cap, mid-cap or small-cap stocks, or growth or value stocks may underperform other
market segments or the equity markets as a whole. You can find additional information regarding these risks in the fund’s
prospectus.
Exchange-Traded Funds (ETFs)
ETFs are typically investment companies that are legally classified as open-end mutual funds or unit investment trusts. ETFs
differ from traditional mutual funds in that ETF shares are listed on a securities exchange. Shares can be bought and sold
throughout the trading day like shares of other publicly traded companies. ETF shares may trade at a discount or premium
to their net asset value. This difference between the bid price and ask price is often referred to as the “spread.” The spread
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varies over time based on the ETF’s trading volume and market liquidity and is generally lower if the ETF has a lot of trading
volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Liquidity risks are higher
for ETFs with a large spread. ETFs may be closed and liquidated at the discretion of the issuing company.
International Investing
The risks of investing in foreign securities include loss of value because of political or economic instability; nationalization,
expropriation or confiscatory taxation; changes in foreign exchange rates and foreign exchange restrictions; settlement
delays; and limited government regulation (including less stringent reporting, accounting, and disclosure standards than are
required of U.S. companies). These risks may be greater with investments in emerging markets. Certain investments utilized
by the Firm may also contain international securities.
Cash and Cash Equivalents
A portion of your assets may be invested in cash or cash equivalents to achieve your investment objective, provide ongoing
distributions, and/or take a defensive position. Cash holdings may result in a loss of market exposure.
Alternative Investments (Private Funds)
Alternative investments are illiquid investments and do not trade on a national securities exchange. Alternative investments
typically include investments in direct participation program securities (partnerships, limited liability companies, business
development companies or real estate investment trusts), commodity pools, private equity, private debt, or hedge funds.
Alternative investments are subject to various risks, such as illiquidity and property devaluation based on adverse economic
and/or real estate market conditions.
Alternative investments are not suitable for all investors. Investors considering an investment strategy utilizing alternative
investments should understand that alternative investments are generally considered speculative in nature and may involve
a high degree of risk, particularly if concentrating investments in one or few alternative investments. These risks are
potentially greater and substantially different than those associated with traditional equity or fixed income investments.
Additional information regarding these risks can be found in the product’s prospectus or offering documents.
Our recommendation or selection of private investments is generally limited to private funds, and in all cases, the client will
receive offering materials and complete subscription forms to execute the investment. We are able to give advice on other
private offerings if requested by the client. Clients should carefully review the offering documents provided in order to fully
understand the risks involved in a particular private fund. Private funds are considered illiquid investments, as they usually
impose a lock-up period or restriction on redemptions.
These investments (e.g., private equity) may be exempt from registration under federal securities laws, may have limited or
no transparency as to the underlying investments, and are generally available only to “accredited” or “qualified investors.”
Such investors are assumed to be sophisticated purchasers who have little or no need for liquidity from such investments
and can withstand the loss of some or all of their investment.
Limitations on withdrawal rights and non-tradability of interests create higher liquidity risk, and such securities should be
viewed as long-term investments. Clients using these products and strategies must be able to tolerate this illiquidity by
reserving sufficient resources to meet all obligations.
Partnership and fee expenses may be a higher percentage of net assets than traditional investment strategies and may
include performance or incentive fees. The duration of private fund investments with longer-term securities are more
sensitive to interest rates and include the possibility of more volatility than other investments.
In addition, the underlying investments of each private fund carry risks that should be considered. This is not an exhaustive
list of potential or actual risks in any particular private placement, and additional important information is found in the
specific security’s offering materials. Clients generally must execute separate subscription documents to invest in private
funds.
Margin
•
While some HWM clients may choose margin accounts, it’s crucial to understand the significant risks involved:
•
Losses can exceed deposits: A security price drop might require additional funds to avoid forced selling of your
assets, potentially exceeding your initial investment.
Forced selling: If your account value falls below minimum requirements, the brokerage can sell your assets to cover
the loan, leaving you responsible for any shortfall.
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It is important that clients take time to learn about the risks involved in trading securities on margin. Clients should consult
HWM regarding any concerns they may have with their margin accounts.
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 HWM or the integrity of HWM’s management. HWM has no information applicable
to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
HWM principal and owner, David Hohimer, is also the owner of Risk & Liability Consultants LLC (“R&LC”), a commercial
loan broker specializing in connecting small business owners and investors with loans for their business or commercial
uses, such as multifamily housing, construction, retail or refinancing an existing commercial loan. R&LC also provides
licensed mortgage brokerage services and offers life insurance products through licensed agents and insurance agencies.
Certain Supervised Persons of HWM are affiliated with R&LC and are licensed insurance agents.
HWM principal and owner, David Hohimer, is also the owner of LendinCo LLC (“LendinCo”), which provides residential
lending services. Certain Supervised Persons of HWM are affiliated with LendinCo and are licensed loan officers. HWM
refers clients of the firm to LendinCo based on their lending needs. Certain clients of LendinCo may be referred to HWM
Tax & Accounting Unit
based on their wealth management needs.
Certain Supervised Persons of HWM also provide tax planning, tax preparation, and accounting services through HWM’s Tax
& Accounting unit. This dual role creates a conflict of interest because these individuals have a financial incentive to
recommend the Firm’s tax services to advisory clients for additional compensation.
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Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading
HWM strives to identify, eliminate and/or mitigate conflicts and potential conflicts of interest and has adopted policies,
procedures, and oversight mechanisms to address such conflicts and potential conflicts of interest. HWM has specifically
adopted a Code of Ethics in compliance with Rule 204A-1 under the Investment Advisers Act of 1940. The Code of Ethics
emphasizes HWM’s fiduciary obligation to put client interests first and is designed to ensure personal securities
transactions, activities, and interests of employees will not interfere with the responsibilities to make decisions in the best
interest of clients.
HWM 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, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the
reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things.
All employees at HWM attest annually to having read and understood their obligation under the Code of Ethics.
HWM anticipates that, in appropriate circumstances, consistent with clients’ investment objectives, it will cause accounts
over which HWM has management authority to effect and will recommend to investment advisory clients or prospective
clients, the purchase or sale of securities in which HWM, its affiliates and/or clients, directly or indirectly, have a position of
interest. HWM’s employees and persons associated with HWM are required to follow HWM’s Code of Ethics. Subject to
satisfying this policy and applicable laws, officers, directors, and employees of HWM may trade for their own accounts in
securities which are recommended to and/or purchased for HWM’s clients. The Code of Ethics is designed to assure that the
personal securities transactions, activities and interests of the employees of HWM 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 of Ethics, certain classes of securities have been designated as
exempt transactions, based upon a determination that these would materially not interfere with the best interest of HWM’s
clients. Nonetheless, because the Code of Ethics 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, and to reasonably prevent conflicts of interest between HWM and
its clients.
Certain affiliated accounts may trade in the same securities with client accounts on an aggregated basis when consistent
with HWM’s obligation of best execution. In such circumstances, the affiliated and client accounts will share commission
costs equally and receive securities at a total average price. HWM will retain records of the trade order (specifying each
participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed
orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any
exceptions will be explained on the order.
Prior written authorization from the Chief Compliance Officer is mandatory for employees seeking to acquire securities in
initial public offerings or private placements, or to serve on the boards of directors of public or private companies. Such
actions will only be approved if deemed congruent with both client interests and applicable securities laws and regulations.
Employees serving on boards are obligated to recuse themselves from investment decisions potentially conflicting with
client interests.
HWM’s clients or prospective clients may request a copy of the firm’s Code of Ethics by contacting us at
dstlouis@hohimerwealthmanagement.com.
It is HWM’s policy that the firm will not affect any principal or agency cross-securities transactions for client accounts. HWM
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 hedge 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 arise where an adviser is dually registered as a broker-dealer or has
an affiliated broker-dealer.
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Item 12 – Brokerage Practices
Selection and Recommendation of Broker-Dealers
Though HWM recommends brokers with which we’ve negotiated pricing on behalf of our clients, we do not have
discretionary authority to select brokers. We endeavor to select broker-dealers that will provide the best services at the
lowest commission rates possible. The reasonableness of commissions is based on the broker’s ability to provide
professional services, competitive commission rates, research and other services that will help HWM provide investment
management services to clients. HWM may recommend brokers who provide useful research and securities transaction
services even though a lower commission may be charged by a broker who offers no research services and minimal
securities transaction assistance.
HWM utilizes Trade-PMR, Inc. (“Trade-PMR”), Charles Schwab & Co., Inc. (“Schwab”), for brokerage and trade execution
services. Trade-PMR clears trades and custodies assets with First Clearing Corp. (“FCC”). First Clearing is a trade name used
by Wells Fargo Clearing Services, LLC., a non-bank affiliate of Wells Fargo & Company. Trade-PMR acts as an introducing
broker dealer on a fully disclosed basis and is not affiliated with FCC. Trade-PMR, FCC, and Schwab are FINRA/SIPC member
broker-dealers. The brokerage commissions and/or transaction fees charged by these broker-dealers are exclusive of and in
addition to HWM’s fee. HWM regularly reviews the reasonableness of the compensation received by the broker-dealers used
for executing client transactions in an effort to ensure that our clients receive favorable execution consistent with our
fiduciary duty. Factors which HWM considers in recommending broker-dealers to clients include, but are not limited to,
their respective financial strength, reputation, execution, pricing, research, and service. The commissions and/or transaction
fees charged by these brokers may be higher or lower than those charged by other broker-dealers.
Effective October 7, 2019, Schwab has eliminated commissions for online trades of U.S. equities, ETFs, and options (subject
to $0.65 per contract fee). We encourage you to review your broker-dealer’s pricing to compare the total costs of entering a
wrap fee arrangement versus a non-wrap arrangement. You will still incur commissions and fees at Schwab for certain types
of transactions in a non-wrap fee arrangement. To see what you would pay for transactions in a non-wrap account, please
refer to Schwab’s most recent pricing schedules available at www.schwab.com/aspricingguide.
The commissions paid by HWM’s clients are intended to be consistent with HWM’s duty to obtain “best execution.”
However, a client may pay a commission that is higher than what another qualified broker-dealer might charge to affect the
same transaction when HWM determines, in good faith, that the commission is reasonable in relation to the value of the
brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost,
but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-
dealer’s services, including among others, execution capability, commission rates, and responsiveness. Consistent with the
foregoing, while HWM will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for
client transactions.
Independent Managers selected by clients to manage clients’ assets may request the discretion to select brokers and
negotiate commissions on behalf of a client. HWM will not have control over trading execution by such managers. Clients
should review the Form ADV disclosure documents of such managers for additional information regarding their trading
practices.
Products & Services Available to Us from Broker-Dealers
The broker-dealers we recommend to clients provide HWM with access to its institutional trading and custody services,
which are typically not available to retail investors. These brokerage services include the execution of securities
transactions, research, and access to mutual funds and other investments that are otherwise generally available only to
institutional investors or would require a significantly higher minimum initial investment. Other benefits we may receive
include receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk that exclusively
services its participants; access to block trading which provides the ability to aggregate securities transactions and then
allocates the appropriate shares to client accounts; and access to an electronic communication network for client order
entry and account information. Schwab’s support services are generally available on an unsolicited basis and at no charge to
us as long as we maintain a total of at least $10 million of our clients’ assets in accounts at Schwab.
HWM also receives other services from broker-dealers (or third-party vendors with which they do business) to help us
manage and further develop our business enterprise. These services include educational conferences and events;
technology, 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. Fees for these
services may be waived, discounted, or compensated by the broker-dealer. Trade-PMR also provided HWM with nominal
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funding to assist with startup expenses establishing the business entity. These fees are sometimes known as soft dollar
benefits. Irrespective of these direct and indirect benefits to our clients, we strive to enhance our clients’ experience and
always put the needs of our clients first.
Brokerage for Client Referrals
When selecting broker-dealers for the execution of client securities transactions, HWM does not consider whether we will
receive any client referrals from the broker-dealer or any other third-party.
Directed Brokerage
As HWM will not request the discretionary authority to determine the broker-dealer to be used or the commission rates to
be paid, clients must direct HWM as to the broker-dealer to be used. The commissions and transaction fees charged by these
broker-dealers could be higher or lower than those charged by other custodians and broker-dealers. In directing the use of a
particular broker-dealer, it should be understood that HWM will not have authority to negotiate commissions among
various broker-dealers or obtain volume discounts. As such, best execution may not be achieved. Not all investment advisers
require clients to direct the use of specific broker-dealers.
Aggregation of Orders
HWM will generally block trades where possible and when advantageous to clients. Certain trades will be effected
independently. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from
multiple client accounts so long as transaction costs are shared equally and on a pro-rated basis between all accounts
included in the block. Block trading allows HWM to execute equity or fixed income trades in a timely, equitable manner and
to reduce overall commission charges to clients. Clients who do not provide HWM with discretion will not participate in
block trades, and their trades in similar securities will be placed with brokers after trades for discretionary accounts.
Accounts owned by supervised persons of our firm may participate in block trading with your accounts; however, these
individuals will not be given preferential treatment of any kind.
Private Fund Allocation
Private funds are “limited offerings” due to their restricted investor pool. HWM tailors these investments to individual
clients, considering their sophistication, risk tolerance, qualifications, objectives, and available assets. HWM strives for
equitable allocation, however, given these differing factors, the allocation of investment opportunities in Private Funds to
clients is mainly subjective, and not all qualifying clients will be provided an investment opportunity. Notably, HWM
employees may occasionally co-invest with clients in certain funds. To mitigate potential conflicts, such employee
participation requires prior written Chief Compliance Officer approval. It is imperative that qualifying clients receiving a
private fund recommendation thoroughly review offering documents before investing to fully grasp associated risks and
potential conflicts.
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Item 13 – Review of Accounts
For those clients to whom HWM provides investment management services, HWM performs periodic account reviews which
may be in conjunction with the preparation of client’s quarterly reports. This informal review may include assessing client
goals and objectives, monitoring the portfolios and addressing the need to rebalance. Individual securities held in client
accounts will be periodically monitored by HWM, while the firm will monitor any selected third-party managers on a
quarterly basis. Accounts are reviewed in the context of each client’s stated investment objectives and guidelines. More
frequent reviews may be triggered by material changes in variables such as the client’s individual circumstances, market
conditions, or the political or economic environment.
Additional reviews that HWM may periodically perform include tax-planning, cash-flow needs, as well as charitable giving,
insurance, and estate planning. All investment advisory clients are encouraged to discuss their needs, goals, and objectives
with HWM and to keep HWM informed of any changes thereto. HWM shall contact ongoing investment advisory clients at
least annually to review its previous services and/or recommendations and to discuss the impact resulting from any
changes in the client’s financial situation and/or investment objectives.
Reports
Unless otherwise agreed upon, clients are provided with transaction confirmation notices and regular summary account
statements directly from the broker-dealer or custodian for the client accounts. Those clients to whom HWM provides
investment advisory services may also receive a written report from HWM that may include such relevant account and/or
market-related information such as an inventory of account holdings and account performance on a quarterly basis.
As a convenience to our clients, in addition to reporting on clients’ financial assets, at a client’s request, the client’s global
consolidated report may also include certain non-financial assets (e.g., real assets). In such instances, HWM relies on the
client to provide current and accurate price or other valuation information for those assets to be included in the client’s
consolidated account report. HWM does not independently verify, and expressly disclaims responsibility for, the accuracy of
any non-financial asset values clients provide to us to include in their reporting.
Item 14 – Client Referrals and Other Compensation
HWM has entered a contractual relationship with SmartAsset (Referral Source) to receive referrals generated from online
marketing efforts. These are paid arrangements whereby HWM has agreed to pay Referral Source a fee for potential clients
referred to the firm through the Referral Source’s online marketing efforts.
Individuals that contact the Referral Source, either directly or via an online inquiry, will be connected with a potential
financial advisor, including HWM. HWM’s payment to the referral sources is based on the number and asset level of referrals
provided and not based on the number of new clients attained. Referral Sources do not proactively call or speak to
individuals about HWM, but if an individual contacts a Referral Source for a recommended financial provider, the individual
can be connected to HWM. At that time, the Referral Source will provide the individual a Solicitor Disclosure Statement
(detailing among other things, the fee HWM pays to the Referral Source). Individuals referred to HWM by a Referral Source
are not required or obligated in any way to become a client of HWM.
However, as a courtesy to clients, HWM may introduce clients to other investment and non-investment related service
providers/professionals, such as accountants, attorneys, insurance providers, other luxury service providers, etc. An
example of such recommendation is HWM’s relationship with Wealth.com, which is primarily known as a technology
platform focused on modernizing and streamlining estate planning. HWM does not receive any financial or economic benefit
in exchange for these referrals, however these professional service providers may recommend HWM to their clients. The
client is under no obligation to engage the services of any such introduced professional. The client retains absolute
discretion over all such implementation decisions and is free to accept or reject any introduction or recommendation from
HWM. Although HWM may have experience with these service providers, HWM has not performed due diligence on these
service providers and is not responsible for the services provided by these service providers and/or professionals. HWM is
not responsible for any losses caused by the actions of any third party recommended by HWM, including, without limitation,
any accounting or legal professional services.
As noted in Item 12, HWM will receive additional benefits from Trade-PMR which includes electronic systems that assist in
the management of HWM client accounts, access to research, the ability to directly debit client fees, 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), pricing information and other market
data, assist with back-office functions, recordkeeping and client reporting.
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The custodians and brokers may also make available to us other products and services that benefit us but may not directly
benefit clients or their accounts. These products and services assist us in managing and administering our clients’ accounts.
They include investment research from the custodians and from third parties. We may use this research to service all or a
substantial number of our clients’ accounts, including accounts not maintained at the custodians.
Additionally, custodians and brokers may provide the following services that benefit HWM: (i) educational conferences and
events; (ii) consulting on technology, compliance and business needs; and (iii) publications and conferences on practice
management and business succession.
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Item 15 – Custody
When you establish a relationship with our firm for investment management services, your assets will be maintained by a
bank, broker-dealer, mutual fund transfer agent or other such institution deemed a “qualified custodian” by the SEC. We rely
on the custodian to price and value assets, execute and clear transactions, maintain custody of assets in your account and
perform other custodial functions. HWM does not maintain physical possession of any client account assets.
Nevertheless, HWM is deemed to have custody due to its authority over certain accounts to distribute assets subject to a
third-party standing letter of authorization. HWM will undergo a surprise custody examination by an independent public
accountant each calendar year for any such accounts.
Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and
maintains the client’s investment assets. HWM urges you to carefully review such statements and compare such official
custodial records to any performance reports that we may provide to you. Our reports may vary from custodial statements
based on accounting procedures, reporting dates, or valuation methodologies of certain securities. You should promptly
notify us if you do not receive account statements from your custodian at least quarterly or if you believe the information on
your account statements is inaccurate.
Item 16 – Investment Discretion
HWM usually receives discretionary authority from the client at the outset of an advisory relationship to select the identity
and amount of securities to be bought or sold. Additionally, HWM may manage client assets on a non-discretionary basis. In
all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the
particular client account. Investment guidelines and restrictions must be provided to HWM in writing.
Item 17 – Voting Client Securities
As a general policy, HWM will retain proxy voting authority for clients that have given us the authority to do so. In such
cases, we will follow the proxy voting guidelines outlined in our Proxy Voting Policies and Procedures. You may obtain a
copy of our Proxy Voting Policies and Procedures and/or a record of ballots voted upon by contacting
dstlouis@hohimerwealthmanagement.com. Clients may also elect to have us participate in class action lawsuits and related
settlements on their behalf. In such cases, we utilize a third-party service provider to assist the firm with the filing process,
who receives 20% of any settlement awarded to the client for their services.
Item 18 – Financial Information
Registered investment advisers are required to provide clients with certain information or disclosures about the firm’s
financial condition. Hohimer Wealth Management has no financial commitment that impairs its ability to meet contractual
or fiduciary commitments to its clients and has never been the subject of a bankruptcy proceeding.
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