Overview

Headquarters
Reston, VA
Average Client Assets
$4.1 million
Minimum Account Size
$750,000
SEC CRD Number
127927

Fee Structure

Primary Fee Schedule (FORM ADV 2A)

MinMaxMarginal Fee Rate
$0 $1,000,000 1.00%
$1,000,001 $4,000,000 0.75%
$4,000,001 $7,000,000 0.50%
$7,000,001 $10,000,000 0.40%
$10,000,001 and above 0.30%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $37,500 0.75%
$10 million $59,500 0.60%
$50 million $179,500 0.36%
$100 million $329,500 0.33%

Clients

HNW Share of Firm Assets
92.76%
Total Client Accounts
1,068
Discretionary Accounts
1,068

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection

Regulatory Filings

Additional Brochure: FORM ADV 2A (2026-03-27)

View Document Text
ITEM 1 – COVER PAGE HOPWOOD FINANCIAL SERVICES, INC. FORM ADV PART 2A: DISCLOSURE BROCHURE MARCH 25, 2026 10740 Parkridge Blvd. Suite 150 Reston, VA 20191 Tel: (703) 787-0008 www.hopwoodfinancial.com This Disclosure Brochure provides information about the qualifications and business practices of Hopwood Financial Services, Inc. If you have any questions about the contents of this Disclosure Brochure, please contact us; our contact information is listed to the right. Additional information about Hopwood Financial Services, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. The information contained in this Disclosure Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any State Securities Administrator. Furthermore, the term “registered investment advisor” is not intended to imply that Hopwood Financial Services, Inc. has attained a certain level of skill or training. FORM ADV PART 2A: DISCLOSURE BROCHURE ITEM 2 – MATERIAL CHANGES While there are no material changes to report since the annual update filing on June 6, 2025, this Disclosure Brochure has been reformatted and rewritten to provide clearer, more detailed information about our advisory practice. Hopwood Financial Services, Inc. Page 2 of 14 FORM ADV PART 2A: DISCLOSURE BROCHURE ITEM 3 – TABLE OF CONTENTS Item 2 – Material Changes ............................................................................................................................................ 2 Item 3 – Table of Contents ............................................................................................................................................ 3 Item 4 – Advisory Business ........................................................................................................................................... 4 Item 5 – Fees & Compensation .................................................................................................................................... 7 Item 6 – Performance-Based Fees & Side-By-Side Management ............................................................................... 9 Item 7 – Types of Clients .............................................................................................................................................. 9 Item 8 – Methods of Analysis, Investment Strategies & Risk of Loss ........................................................................... 9 Item 9– Disciplinary Information.................................................................................................................................. 11 Item 10– Other Financial Industry Activities & Affiliations ........................................................................................... 11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions & Personal Trading .................................. 11 Item 12 – Brokerage Practices.................................................................................................................................... 11 Item 13 – Review of Accounts..................................................................................................................................... 13 Item 14 – Client Referrals & Other Compensation ..................................................................................................... 13 Item 15 – custody ........................................................................................................................................................ 13 Item 16 – Investment Discretion ................................................................................................................................. 14 Item 17 – Voting Client Securities ............................................................................................................................... 14 Item 18 – Financial Information................................................................................................................................... 14 Hopwood Financial Services, Inc. Page 3 of 14 FORM ADV PART 2A: DISCLOSURE BROCHURE ITEM 4 – ADVISORY BUSINESS Who We Are Hopwood Financial Services, Inc. (“the Firm”, “we,” “us,” “our”) is an independent, fee-only financial planning and investment management firm that provides a range of financial advisory services designed to assist clients in pursuing their financial goals, including long-term financial stability and independence. The Firm is a Virginia corporation registered with the U.S. Securities and Exchange Commission (“SEC”) and was founded in 2003 by Herbert G. Hopwood. The following persons own and control the Firm: Name Title CRD# Herbert G. Hopwood President & Chief Compliance Officer 1605128 Kelvin J. Galvin Executive Vice President 5578925 Our mission is to provide comprehensive financial planning and investment management services designed to help clients navigate the complexities of their financial lives with clarity and confidence. We strive to act as a central resource for our clients’ financial decision-making by coordinating investment management, financial planning, and other key components that shape each client’s overall financial picture. In fulfilling this mission, we are guided by several core principles. We are committed to acting as fiduciaries and providing full and transparent disclosure regarding our services, fees, and potential conflicts of interest. We approach each client relationship with empathy and professionalism, recognizing that financial decisions are closely tied to personal goals and circumstances. We aim to deliver a high standard of client service and maintain a disciplined awareness of investment and financial risks when developing and implementing recommendations. Assets Under Management As of December 31, 2025, our assets under management were as follows: Discretionary Accounts: $750,255,685 Non-Discretionary Accounts: $0 What We Do We provide customized investment management and financial planning services primarily to high-net-worth individuals and associated trusts, estates, IRAs, pension and profit-sharing plans, and other legal entities. We generally invest client assets in domestic and international stocks, bonds, mutual funds, and exchange-traded funds (“ETFs”). Investment Management Services We provide discretionary investment advisory services on a fee-only basis. Our annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under the Firm’s management. We provide investment advisory services specific to the needs of each client. We work with each client to establish an appropriate investment profile. Clients choose from various allocations of equities, fixed income, and cash, and can impose reasonable restrictions on the Firm’s management of their accounts, which are mutually agreed upon in advance. Thereafter, we will allocate investment assets consistent with the designated investment objectives. Once allocated, we provide ongoing monitoring and review of account performance, asset allocation, and client investment objectives. Personal Financial Planning and Consulting Services We provide financial planning and consulting services on a stand-alone basis, which may include both investment- and non-investment-related matters, such as estate planning, insurance planning, and other financial planning topics, depending on the client's needs and requests. Prior to providing these services, clients are required to enter into a written agreement with the “Firm that outlines the terms and conditions of the engagement, including termination provisions, the scope of services to be provided, and the portion of the fee that must be paid before the Firm begins work. At a client’s request, we may recommend the services of other professionals to assist with the implementation of planning recommendations. Clients are under no obligation to engage any professional we recommend. Each client Hopwood Financial Services, Inc. Page 4 of 14 FORM ADV PART 2A: DISCLOSURE BROCHURE retains full discretion regarding whether to follow any recommendation and whether to engage any unaffiliated professional. If a client chooses to engage a recommended professional, that professional operates independently of the Firm. Should any dispute arise related to the services provided by that professional, the client agrees to seek recourse directly from that professional. The engaged licensed professional (such as an attorney, accountant, or insurance agent), and not the Firm, is solely responsible for the quality and competency of the services they provide. Retirement Consulting Services We may also be engaged to provide pension consulting services. In this capacity, the Firm assists sponsors of self- directed retirement plans with the selection and/or monitoring of investment options, generally including open-end mutual funds, from which plan participants may choose when directing the investments in their individual retirement plan accounts. In addition, at the plan sponsor's request, we may provide participant education to help plan participants understand available investment options and identify an appropriate investment strategy for their retirement plan accounts. The specific terms and conditions of these services are typically outlined in a written agreement between the Firm and the plan sponsor. Additional Disclosures Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As described above, we may provide financial planning and related consulting services at a client’s request. Neither the Firm nor its investment adviser representatives assist with the implementation of a financial plan unless such services are specifically agreed to in writing. We do not continuously monitor a client’s financial plan, and it remains the client’s responsibility to request a review of the plan with us if they wish to revisit or update prior recommendations. We may also provide financial planning and consulting services on non-investment matters, including estate, tax, and insurance planning. However, the Firm does not operate as a law firm, accounting firm, or insurance agency. Accordingly, no portion of the Firm’s services should be interpreted as providing legal, accounting, or insurance implementation services. The Firm does not prepare estate planning documents or tax returns, nor does it sell insurance products. At a client’s request, we may recommend the services of other professionals to assist with the implementation of certain non-investment matters (such as attorneys, accountants, or insurance agents). Clients are under no obligation to engage any professional recommended by the Firm. Each client retains full discretion to accept or reject any recommendation and to engage any unaffiliated professional. If a client elects to engage a recommended professional, that professional operates independently of the Firm. If any dispute arises in connection with services provided by such professional, any claims or recourse should be directed to that professional. The engaged licensed professional (e.g., attorney, accountant, or insurance agent), and not the Firm, is solely responsible for the quality and competency of the services provided. Retirement Rollovers-Potential for Conflict of Interest. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). We do not provide rollover recommendations. However, upon request, we may provide educational materials to clients considering a rollover. No client is under any obligation to roll over retirement plan assets to an account managed by the Firm. Cash Positions. The Firm treats cash as an asset class. As such, unless determined to the contrary by the Firm, all cash positions (money markets, etc.) shall be included as part of assets under management for purposes of calculating our advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), the Firm may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending on current yields, our advisory fee could at any time exceed the interest paid by the client’s money market fund. Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits be swept to and/or initially maintained in a specific custodian-designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion the Firm shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless the Firm reasonably anticipate that it will utilize the cash proceeds during the subsequent 30-day Hopwood Financial Services, Inc. Page 5 of 14 FORM ADV PART 2A: DISCLOSURE BROCHURE period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. The above does not apply to the cash component maintained within our actively managed investment strategies (the cash balances for which shall generally remain in the custodian-designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager, and cash balances maintained for fee billing purposes. The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any Hopwood Financial unmanaged accounts. Use of Mutual and Exchange-Traded Funds. In addition to our investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange- traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Third-Party Managers. We may allocate a portion of a client’s investment assets among unaffiliated third-party managers (“Independent Manager(s)”) in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager(s) will have day-to-day responsibility for the active discretionary management of the allocated assets. We will continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation, and client investment objectives. We generally consider the following factors when recommending Independent Manager(s): the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Manager(s) are exclusive of, and in addition to, our ongoing investment advisory fee. Independent Managers shall debit their fees directly from client accounts. The Independent Manager’s fee shall be communicated to the client upon their engagement, and any increase or changes regarding the Independent Manager's billing practices shall be subsequently communicated to the client. Our advisory fee is set forth in the fee schedule below. Bitcoin, Cryptocurrency, and Digital Assets. We do not recommend or advocate for the purchase of, or investment in, Bitcoin, cryptocurrencies, or digital assets. Such investments are considered speculative and carry significant risk. For clients who want exposure to Bitcoin, cryptocurrencies, or digital assets, we may advise the client to consider a potential investment in corresponding exchange-traded securities or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Bitcoin and cryptocurrencies are digital assets that can be used for various purposes, including transactions, decentralized applications, and speculative investments. Most digital assets use blockchain technology, an advanced cryptographic digital ledger to secure transactions and validate asset ownership. Unlike conventional currencies issued and regulated by monetary authorities, cryptocurrencies generally operate without centralized control, and their value is determined by market supply and demand. While regulatory oversight of digital assets has evolved significantly since their inception, they remain subject to variable regulatory treatment globally, which may impact their risk profile and liquidity. Given that cryptocurrency investments are speculative and subject to extreme price volatility, liquidity constraints, and the potential for total loss of principal, the Firm does not exercise discretionary authority to purchase cryptocurrency investments for client accounts. Any investment in cryptocurrencies must be expressly authorized by the client. Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility, regulatory risk, technological risk, security and custody risk, and complete loss of principal. Portfolio Activity. The Firm has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, we will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, mutual fund manager tenure, style drift, and/or a change in the client’s investment objectives. Based upon these factors, there may be extended periods of time when we determine that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described below during periods of account inactivity. ByAllAccounts|Yodlee®. The Firm, in conjunction with the services provided by ByAllAccounts, Inc. |Yodlee®, provides periodic comprehensive reporting services that can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets managed by us (the “Excluded Assets”). The client and/or Hopwood Financial Services, Inc. Page 6 of 14 FORM ADV PART 2A: DISCLOSURE BROCHURE their other advisors that maintain trading authority, and not the Firm, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless otherwise specifically agreed to, in writing, our service relative to the Excluded Assets is limited to reporting only. The sole exception to the above shall be if we are specifically engaged to monitor and/or allocate the assets within the client’s 401(k) account maintained away at the custodian directed by the client’s employer. As such, except with respect to the client’s 401(k) account (if applicable), we do not maintain any trading authority for the Excluded Assets. Rather, the client and/or the client’s designated other investment professional(s) maintain supervision, monitoring and trading authority for the Excluded Assets. If we are asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and we shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that the Firm provide investment management services for the Excluded Assets, the client may engage us to do so pursuant to the terms and conditions of the Investment Advisory Agreement between the Firm and the client. Client Obligations. In performing its services, the Firm shall not be required to verify any information received from the client or from the client’s other designated professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify the Firm if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising our previous recommendations and/or services. Cybersecurity Risk. The information technology systems and networks that Hopwood Financial and its third-party service providers use to provide services to the Firm’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in our operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and the Firm are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although we have established procedures to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that we do not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Disclosure Statement. A copy of the Firm’s written disclosure statement and client relationship summary, as set forth on Part 2 of Form ADV and Form CRS, respectively, shall be provided to each client prior to, or contemporaneously with, the execution of an advisory agreement. ITEM 5 – FEES & COMPENSATION Investment Management Fees Investment management services are offered on the following asset-based, tiered fee schedule: Account Value Annual Fee Rate Not to Exceed Up to and including $1,000,000 1.00% $1,000,001 up to and including $4,000,000 0.75% $4,000,001 up to and including $7,000,000 0.50% $7,000,001 up to and including $10,000,000 0.40% Greater than $10,000,000 0.30% This is a tiered fee schedule, which means the actual fee is charged on each amount at the respective rate and is reduced only for the amount above that threshold. Investment Management fees will be debited from the client’s account quarterly, in arrears, by the custodian as instructed by the Firm. The investment management fee is calculated by multiplying the portion of the Account’s total market value that falls within each tier by one-fourth of that tier’s annual percentage rate (e.g., 1.00% ÷ 4 = 0.25%), then summing the totals. Hopwood Financial Services, Inc. Page 7 of 14 FORM ADV PART 2A: DISCLOSURE BROCHURE Hopwood Financial Institutional Bond Program In conjunction with the Firm’s Investment Management Services, we may allocate a portion of a client’s investment assets among unaffiliated Independent Managers as part of the Firm’s Institutional Bond Program. Client assets managed through the Institutional Bond Program will be subject to an additional annual fee of up to 0.11%, billed quarterly in advance by the Independent Manager. Institutional Bond Program accounts are subject to a minimum asset level of $125,000. Clients who do not wish to participate in the Firm’s Institutional Bond Program may direct us, in writing, accordingly. Unless otherwise agreed to in writing, we will combine the account values of family members (i.e., spouse and dependent children) living in the same household to determine the applicable management fee. Combining account values may increase the total managed assets, which could result in a reduced management fee based on the breakpoints in our tiered fee schedule. Investment management fees will be deducted first from any money market funds or cash balances. If such assets are insufficient to satisfy payment of such fees, a portion of the account assets will be liquidated to cover the fees. Investment management services begin when assets begin to fund the account. For the beginning calendar quarter, fees will be adjusted pro-rata based upon the number of calendar days in the calendar quarter that the agreement was effective. Most clients authorize the Firm to deduct fees automatically from their brokerage accounts, but clients may request that we send quarterly invoices to be paid by check. In either case, a copy of the bill is provided to each client stating the amount that was charged and how the fee was calculated. The Firm reserves the right to charge a new account processing fee of up to $350 to defray the cost of transfers, paperwork and the monitoring of transfers from existing accounts. Calculation of distributions, issuance of checks, special reports and other services, which are not routine investment management services, may be billed on an hourly basis at the then prevailing rates (current maximum of $250/hour). All fees are to be billed and are due after services are rendered. The Firm has waived or negotiated lower fees for certain clients such as charitable organizations, employees’ family members or special circumstances. In accordance with the foregoing, investment advisory fees are negotiable at our discretion, depending upon objective and subjective factors including but not limited to: the amount of assets to be managed; portfolio composition; the scope and complexity of the engagement; the anticipated number of meetings and servicing needs; related accounts; future earning capacity; anticipated future additional assets; the professional(s) rendering the service(s); prior relationships with the Firm and/or its representatives, and negotiations with the client. As a result of these factors, similarly situated clients could pay different fees, the services to be provided by the Firm to any particular client could be available from other advisers at lower fees, and certain clients may have fees different than those specifically set forth above. Either the client or the Firm may terminate the Investment Advisory Agreement at any time. The client is responsible for paying for services rendered up to and including the termination of the Agreement. If a client terminates the Investment Management Agreement with the Firm in the middle of a billing period, we will invoice the client and deduct the applicable fee (unless notified otherwise) for an amount that is prorated based on the number of days that the account was managed during the quarter. If the client’s account is managed in the Institutional Bond Program and billed in advance, the client shall receive a prorated refund of the quarterly management fee based on the number of days remaining in the quarter after the termination notice takes effect. Cash Balances The Firm treats cash as an asset class. As such, unless determined to the contrary by the Firm, all cash positions (money markets, etc.) shall be included as part of assets under management for purposes of calculating our advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), the Firm may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending on current yields, our advisory fee could at any time exceed the interest paid by the client’s money market fund. Deposits & Withdrawals If a client contributes or withdraws $50,000 or more in a given day, the Firm will pro-rate the fees on this contribution or withdrawal for the quarter. Contributions and withdrawals of less than $50,000 in a given day are not prorated. Other Fees & Expenses Hopwood Financial Services, Inc. Page 8 of 14 FORM ADV PART 2A: DISCLOSURE BROCHURE Broker-dealers such as Charles Schwab & Co. Inc. (“Schwab”) and Fidelity Investments (“Fidelity”) charge brokerage commissions, transaction fees, and/or other types of fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other types of fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian. While certain custodians, including Schwab and Fidelity, generally (with the potential exception for large orders) do not currently charge fees on individual equity transactions (including ETFs), others do. There can be no assurance that Schwab or Fidelity will not change their transaction fee pricing in the future. Schwab and Fidelity may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. Clients will incur, in addition to our investment management fee, brokerage commissions and/or transaction fees, and, relative to all mutual fund and exchange-traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Relative to its discretionary investment management services, when beneficial to the client, transactions may be affected through broker-dealers other than the account custodian, in which event, the client generally will incur both the transaction fee charged by the executing broker-dealer and a separate “trade-away” and/or prime broker fee charged by the account custodian (i.e., Schwab or Fidelity). Please see Item 12 - Brokerage Practices for more information. Personal Financial Planning & Consulting Fees Personal financial planning and consulting service fees are generally charged on an hourly basis. Hourly fees range from $350 per hour for most financial planning services to $125 per hour for purely administrative functions. Such fees shall be mutually agreed upon in advance by the client and the Firm and shall be due and payable when services are rendered. A client may cancel the financial planning agreement and receive a full refund if the Firm is notified within five business days after signing an agreement. If cancellation occurs thereafter, the client is responsible only for fees and expenses incurred to that point. In such an event, an itemized invoice will be provided documenting the expenses that have been incurred. If any fees have been prepaid by the client, any unearned fees will be returned to the client on a pro- rata basis. ITEM 6 – PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT The Firm does not use a performance-based fee structure because of the potential conflict of interest. Performance- based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client. However, the nature of asset-based fees allows the Firm to participate in the growth of the client’s wealth. This also means that our fees can decline when the client’s portfolio declines in value. ITEM 7 – TYPES OF CLIENTS The Firm generally provides customized investment management and financial planning services to high-net-worth individuals and associated trusts, estates, pension and profit-sharing plans, and other legal entities. The Firm’s minimum relationship size for Investment Management services is generally $750,000, but this amount may be negotiable. There is no minimum asset size for financial planning and consulting services. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES & RISK OF LOSS Our account management services are designed to build, manage, and preserve wealth while maintaining risk levels acceptable to you. We combine your financial needs, investment objectives, time horizon, and risk tolerance to develop an effective investment strategy. Methods of Analysis There is an Investment Committee currently comprised of Herbert G. Hopwood, CFP®, CFA, President, Senior Wealth Advisor, and Kevin J. Galvin, CFP®, CFA, Executive Vice President, Senior Wealth Advisor, and Jason Stinner, CFA, Associate Portfolio Manager. Most individual stock and mutual fund securities are placed on the Firm’s approved list after being reviewed and accepted by the Investment Committee. This analysis varies depending on the security in question. For stocks and bonds, the analysis generally includes a review of: Hopwood Financial Services, Inc. Page 9 of 14 FORM ADV PART 2A: DISCLOSURE BROCHURE  The issuer’s management;  The amount and volatility of past profits or losses;  The issuer’s assets and liabilities, as well as any material changes from historical norms;  Prospects for the issuer’s industry, as well as the issuer’s competitive position within that industry; and  Any other factors considered relevant. For mutual funds and ETFs, the analysis generally includes a review of:  The fund’s management team;  The fund’s historical risk and return characteristics;  The fund’s exposure to sectors and individual issuers;  The fund’s fee structure; and  Any other factors considered relevant. The Investment Committee meets regularly to discuss existing and prospective investments and the investment environment. Investments are evaluated independently, as well as in the context of clients’ existing holdings and sector exposures. The Firm strives to invest for relatively long time horizons, often for several years. However, market developments could cause us to reduce this holding period. Depending on a client’s investment objectives, we might engage in option writing (although not likely). The use of option writing poses additional risks that are discussed in detail with any clients who are considering the use of this investment vehicle. Investment Risks All investing involves a risk of loss. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by the Firm) will be profitable or equal any specific performance level(s). Investors generally face the following types of investment risks:  Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline.   Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk may be caused by external factors independent of the fund’s specific investments, as well as due to the fund’s specific investments. Additionally, each security’s price will fluctuate based on market movement and emotion, which may or may not be due to the security’s operations or changes in its true value. For example, political, economic and social conditions may trigger market events which are temporarily negative, or temporarily positive. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation.  Reinvestment 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.  Liquidity 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.  Financial Risk: Excessive borrowing to finance a business’s operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value.  Borrowing Against Assets/Risks. A client who has a need to borrow money could determine to do so by using: o Margin-The account custodian or broker-dealer lends money to the client. The custodian charges the client interest for the right to borrow money, and uses the assets in the client’s brokerage account as collateral; and, o Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges its investment assets held at the account custodian as collateral. The above-described collateralized loans are generally utilized because they typically provide more favorable interest rates than standard commercial loans. These types of collateralized loans can assist with a pending Hopwood Financial Services, Inc. Page 10 of 14 FORM ADV PART 2A: DISCLOSURE BROCHURE home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are not without potential material risk to the client’s investment assets. The lender (i.e., custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, the Firm does not recommend such borrowing unless it is for specific short-term purposes (i.e., a bridge loan to purchase a new residence). The Firm does not recommend such borrowing for investment purposes (i.e., to invest borrowed funds in the market). If the client were to determine to utilize margin or a pledged assets loan, the Firm would bill on the net value of the assets in the client's account. This could provide the Firm with a disincentive to encourage the client to consider or to continue to use margin.  Covered Call Writing/Risks. Covered call writing is the sale of in-, at-, or out-of-the-money call options against a long security position held in a client portfolio. This type of transaction is intended to generate income. It also serves to create partial downside protection in the event the security position declines in value. Income is received from the proceeds of the option sale. Such income may be reduced or lost to the extent it is determined to buy back the option position before its expiration. There can be no assurance that the security will not be called away by the option buyer, which will result in the client (option writer) to lose ownership in the security and incur potential unintended tax consequences. Covered call strategies are generally better suited for positions with lower price volatility. ITEM 9– DISCIPLINARY INFORMATION The Firm and its employees have not been involved in any legal or disciplinary events that would be material to a client’s valuation of the company or its personnel. ITEM 10– OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS Hopwood Financial Services and its employees do not have any relationships or arrangements with other financial services companies that pose material conflicts of interest. ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING Code of Ethics The Firm has adopted a written Code of Ethics that is applicable to all employees. Among other things, the code requires the firm and its employees to act in clients’ best interests, abide by all applicable regulations, avoid even the appearance of insider trading, and pre-clear and report on many types of personal securities transactions. The Firm’s restrictions on personal securities trading apply to employees, as well as employees’ family members living in the same household. A copy of the Firm’s Code of Ethics is available upon request. The Firm’s employees are generally permitted to trade alongside client accounts as long as they receive the average price that is applicable to clients and pay their share of any transaction costs. However, no employees are allowed to participate in partially filled orders until all clients’ orders have been filled. The Chief Compliance Officer monitors employee trading, relative to client trading, to ensure that employees do not engage in improper transactions. The Firm maintains a watch list of securities that are being considered for client accounts, as well as securities already held in client accounts. Any proposed employee transaction involving individual securities on the watch list requires pre-clearance from the Chief Compliance Officer. The Chief Compliance Officer does not grant pre-clearance where it would appear that an employee’s trading could disadvantage the Firm’s clients. Under certain circumstances, an employee might invest in a security that is not considered suitable for client accounts because of size, liquidity, or other factors. A change in these factors could result in the security becoming more suitable for clients, but the Chief Compliance Officer might not allow the security to be purchased for client accounts in order to avoid even the appearance of employees trading ahead of clients. In the Firm’s experience, it is rare for an employee’s personal trading to limit clients’ investment opportunities, but such a situation may arise from time to time. ITEM 12 – BROKERAGE PRACTICES The Firm generally recommends that clients arrange for their assets to be held with either Schwab or Fidelity as custodian. We have managed client assets at both custodians for many years and have found them both to offer good services at competitive prices. Hopwood Financial Services, Inc. Page 11 of 14 FORM ADV PART 2A: DISCLOSURE BROCHURE Research and Additional Benefits The Firm receives certain products and services from both Schwab and Fidelity free of charge or at discounted rates. These products and services include:  The receipt of duplicate client confirmations, statements, and other account information;  Direct advisory fee debiting capabilities;  Access to an electronic network for order entry, including the simultaneous entry of trades on behalf of multiple client accounts;  Portfolio management system/ software to support the management of client accounts. Clients whose accounts are held by Schwab or Fidelity do not bear any additional costs in connection with our receipt of the products and services. Furthermore, each custodian’s provision of these products and services is not contingent upon us formally committing any specific amount of business to them. However, the Firm would not receive some of these products and services if client accounts were not held in custody and traded by either custodian. The Firm’s receipt of these products and services creates a conflict of interest in connection with our recommendation of each custodian. Also, some of the products and services listed above benefit clients whose accounts are held by other custodians, which could create a conflict of interest between the clients at the custodians, who are indirectly paying for the products and services, and the clients at other custodians who may benefit from the products and services. The Selection of Trading Counterparties The Firm can typically trade accounts held at Schwab and Fidelity using other broker/dealers. However, each custodian charges clients “trade-away” fees that we believe often outweigh any benefits from trading stocks, mutual funds, or ETFs with other brokers. The availability and pricing of bonds vary more widely, so prior to placing a bond trade, the Firm attempts to determine the competitiveness of the price (and yield) and then executes the trade with the dealer that offers sufficient liquidity and the most favorable pricing. For clients who elect to have their accounts held by firms other than Schwab or Fidelity, our approach is often to trade stocks, mutual funds, and ETFs with the chosen custodian, and to trade bonds with the dealer that offers sufficient liquidity and the most favorable pricing (if possible). Some clients’ accounts are relatively small, in which case the custodian may not allow us to trade through other firms. Other clients may specifically request that their accounts only be traded through a particular broker/dealer. We trade these accounts through the firm chosen by the client, which limits our ability to seek best execution. Trading restrictions may result in materially higher trading costs and reduced returns. Best Execution Reviews On at least an annual basis, the Firm evaluates the pricing and services offered by both Schwab and Fidelity and other trading counterparties with those offered by other reputable firms. The Firm has sought to make a good-faith determination that each custodian and other chosen trading counterparties provide clients with good services at competitive prices. However, clients should be aware that this determination could have been influenced by our receipt of products and services from the respective custodian. Historically, we have concluded that our two primary custodians are as good as, or better than, the other firms that have been considered. We would notify our clients if we were to determine that another firm offered better pricing and services than Schwab Institutional and Fidelity Institutional. Aggregating Trade Orders We often aggregate client trades in an effort to treat all clients fairly. Clients participating in a bunched order receive the same average price and incur trading costs that are the same as would be paid if they were trading individually. Employees may be included side-by-side in bunched client trades. If an order is partially filled, clients will have their orders filled on a randomized basis; we will seek to complete any unfilled client orders at a later date whenever possible. Employees are excluded from bunched trades whenever client orders are only partially filled. Hopwood Financial Services, Inc. Page 12 of 14 FORM ADV PART 2A: DISCLOSURE BROCHURE When trading accounts through our custodians and one or more other broker/dealers, the Firm’s trader may choose to place smaller trades ahead of larger trades when the smaller trades are not expected to materially affect the price or liquidity of the security in question. This practice may result in accounts held at our current custodians trading after other accounts with disproportionate frequency. Trade Errors From time to time, we may make an error in submitting a trade order on your behalf. When this occurs, we may place a correcting trade with the broker-dealer which has custody of your account. Under no circumstances will a client bear a loss due to a trade error caused by the Firm. We will maintain documentation to form an audit trail of all trade errors to substantiate the course of action to correct such errors. Client Referrals The Firm does not compensate Schwab, Fidelity, or any other custodian or broker/dealer for referring client accounts. ITEM 13 – REVIEW OF ACCOUNTS Accounts under the Firm’s management are monitored on an ongoing basis by portfolio managers. In addition, certain Investment Committee members and the Chief Compliance Officer will periodically review the portfolios. Certain Investment Committee members review each account in detail on at least an annual basis, as well as in connection with each client meeting. On at least a quarterly basis, certain Investment Committee members and the Chief Compliance Officer review a number of reports that are designed to identify accounts that are outside the expected ranges for returns, exposure to asset classes, and exposure to industry sectors. Reviews of client accounts will also be triggered if a client changes his or her investment objectives, or if the market, political, or economic environment changes materially. Clients receive account statements directly from their chosen custodian on a monthly basis in addition to confirmations of every trade. We provide our own quarterly reports that supplement the custodial statements from the respective brokerage firm where their assets are held. ITEM 14 – CLIENT REFERRALS & OTHER COMPENSATION Other than the previously described products and services that we receive from Schwab and Fidelity, the Firm does not receive any other economic benefits from non-clients (including outside professionals) in connection with the provision of investment advice and financial planning to clients. Neither the Firm nor its representatives compensate non-supervised persons for client referrals. ITEM 15 – CUSTODY We do not take possession of or maintain custody of client account assets. Physical possession and custody of account assets are maintained with the client’s account custodian. Because clients have authorized us to deduct our advisory fees directly from their accounts and to disburse funds from their accounts to a third-party under a Standing Letter of Authorization (“SLOA”), we are deemed to have limited custody of client assets. Therefore, to comply with regulatory requirements and to protect clients and our advisory practice, we have implemented the following regulatory safeguards:  Client funds and securities will be maintained with a qualified custodian in a separate account in the client’s name.  Authorization to withdraw our advisory fees directly from client accounts will be approved by the client prior to engaging in any portfolio management services.  Any SLOA established with a client to disburse funds to a third-party must follow the conditions outlined in the guidance provided in the SEC Staff’s February 21, 2017 Investment Adviser Association No-Action Letter. In certain circumstances, an employee of the Firm may serve as trustee for a client account and therefore have authority over client assets held with the qualified custodian. As a result of this authority, the Firm is deemed to have custody of those client assets because the employee may have the ability to obtain possession of, or direct the movement of, such assets. In accordance with the SEC Custody Rule (Rule 206(4)-2), the Firm is subject to an Hopwood Financial Services, Inc. Page 13 of 14 FORM ADV PART 2A: DISCLOSURE BROCHURE annual surprise examination conducted by an independent public accountant to verify that client assets are maintained in accordance with applicable regulatory requirements. ITEM 16 – INVESTMENT DISCRETION The Firm has investment discretion over all clients’ accounts unless specifically restricted in our agreement with the client. Clients grant us trading discretion through the execution of a limited power of attorney included in our advisory contract. Clients can place reasonable restrictions on our investment discretion. For example, some clients have asked us not to buy securities issued by companies in certain industries, or not to sell certain securities where the client has a particularly low tax basis. If this is applicable, this must be agreed to in advance and in writing. ITEM 17 – VOTING CLIENT SECURITIES In accordance with its fiduciary duty to clients and Rule 206(4)-6 of the Investment Advisers Act, the Firm has adopted and implemented written policies and procedures governing the voting of client securities. We do not vote proxies on behalf of clients. This is the sole responsibility of each respective client. If a client has specific questions about an action being solicited by the proxy that the client does not understand or needs clarification, the client may contact us, and we will explain the details. Please note that we will not advise clients on how to vote. We do not engage in class action lawsuits on behalf of clients. However, if clients have specific questions, they can contact us, and we will help clarify the details. Any final decision about participating, as well as the handling and oversight of any related paperwork, remains the client’s responsibility. ITEM 18 – FINANCIAL INFORMATION The Firm is not required to include financial information in this Disclosure Brochure, as we do not take physical custody of client funds or securities, nor do we bill client accounts six (6) months or more in advance for an amount exceeding $1,200. We are unaware of any current financial conditions that could impair our ability to fulfill our contractual commitments to clients. Additionally, neither the Firm nor any of our officers or directors has been the subject of a bankruptcy petition in the past 10 years. Hopwood Financial Services, Inc. Page 14 of 14

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