Overview
- Headquarters
- Austin, TX
- Average Client Assets
- $5.4 million
- SEC CRD Number
- 307956
Fee Structure
Primary Fee Schedule (TCG FORM ADV PART 2A - MARCH 2023)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $100,000 | 1.50% |
| $100,001 | $1,000,000 | 1.25% |
| $1,000,001 | $3,000,000 | 1.00% |
| $3,000,001 | $7,000,000 | 0.75% |
| $7,000,001 | $10,000,000 | 0.50% |
| $10,000,001 | and above | Negotiable |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $12,750 | 1.28% |
| $5 million | $47,750 | 0.96% |
| $10 million | $77,750 | 0.78% |
| $50 million | Negotiable | Negotiable |
| $100 million | Negotiable | Negotiable |
Clients
- HNW Share of Firm Assets
- 45.71%
- Total Client Accounts
- 15,595
- Discretionary Accounts
- 14,990
- Non-Discretionary Accounts
- 605
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, Educational Seminars
Regulatory Filings
Additional Brochure: TCG FORM ADV PART 2A - MARCH 2023 (2026-03-30)
View Document Text
HUB Investment Partners
HUB Investment Partners
Form ADV Part 2A Brochure
Form ADV Part 2A Brochure
IARD/CRD No: 307956
March 2026
ITEM 1 – COVER PAGE
HUB Investment Partners, LLC
900 South Capital of Texas Highway, Suite 350
Austin, Texas 78746
512.600.5220
www.hubinvestmentpartners.com
March 31, 2026
Form ADV Part 2A Brochure
This Brochure provides information about the qualifications and business practices of HUB Investment
Partners, LLC (“HUB Investment Partners” or the “Firm”). If you have any questions about the contents
of this Brochure, please contact our Chief Compliance Officer, Mariane Lee at 917-858-2854 or
Mariane.Lee@Hubinternational.com. The information in this Brochure has not been approved or verified
by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority.
Additional information about HUB Investment Partners is available on the SEC’s website at
https://www.adviserinfo.sec.gov/Firm CRD #307956.
HUB Investment Partners
HUB Investment Partners
Form ADV Part 2A Brochure
Form ADV Part 2A Brochure
IARD/CRD No: 307956
March 2026
ITEM 2 – MATERIAL CHANGES
SUMMARY OF MATERIAL CHANGES
Item 4 - Under “Advisory Business” we have updated to disclose our assets under management as of December
31, 2025 and HUB Advisor Desk services. As of 3/31/2026, HUB Investment Advisors, Inc. (“HIA”) and Taylor
Advisors, Inc. (Taylor”) merged into HIP. HIA and Taylor were both affiliates of HIP and under common ownership
and control.
Item 8 – We have added information related to the use of AI to increase our operational efficiency.
Item 10 – We have added information related to our affiliation with HIIS, a HUB International broker-dealer.
Item 14 – We have added information related to Financial Coaches who are affiliated with HUB International and
refer clients to HIP, the compensation paid to these Financial Coaches, and the conflicts of interest this arrangement
presents.
If you would like another copy of this Brochure, please download it from the SEC Website as indicated at Item 1
above or you may request a copy by contacting Mariane Lee, Chief Compliance Officer at 917-858-2854 or
Mariane.Lee@Hubinternational.com.
We encourage you to read this document in its entirety.
ITEM 3 – TABLE OF CONTENTS
Item 1 – Cover Page ..................................................................................................................................... 1
Item 2 – Material Changes ........................................................................................................................... 2
Item 3 – Table of Contents ........................................................................................................................... 2
Item 4 – Advisory Business ......................................................................................................................... 3
Item 5 – Fees and Compensation ................................................................................................................. 4
Item 6 – Performance Based Fees and Side by Side Management .............................................................. 6
Item 7 – Types of Clients ............................................................................................................................. 6
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ...................................................... 6
Item 9 – Disciplinary Information .............................................................................................................. 11
Item 10 – Other Financial Industry Activities and Affiliations .................................................................. 12
Item 11 – Code of Ethics Participation or Interest in Client Transactions and Personal Trading .............. 13
Item 12 – Brokerage Practices ................................................................................................................... 14
Item 13 – Review of Accounts ................................................................................................................... 15
Item 14 – Client Referrals and Other Compensation ................................................................................. 16
Item 15 – Custody ...................................................................................................................................... 17
Item 16 – Investment Discretion ................................................................................................................ 17
Item 17 – Voting Your Securities............................................................................................................... 18
Item 18 – Financial Information ................................................................................................................. 18
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ITEM 4 – ADVISORY BUSINESS
This document, offered by HUB Investment Partners, discloses information about the investment advisory services
we provide and the manner in which we provide them to you, the client.
We are an investment management and financial planning firm with our main office in Austin, Texas. HUB
Investment Partners (formerly known as TCG Advisory Services, LLC until July of 2024) was first established in
2002 and became registered with the Securities & Exchange Commission as an investment adviser in 2020. HUB
Investment Partners (“HIP”) was acquired by HUB International Limited in 2021. HIP’s direct owner is RPW
Holdings, LLC, a HUB International company.
‐
We provide investment advisory services to, pension and profit
sharing plans, defined contribution plans, institutions,
trusts, businesses, state and municipal government retirement plans, public school districts as well as individuals
and high net worth individuals. In designing our services, we consider the client’s financial situation, investment
objectives, time horizon, risk tolerance, and other client needs. Through the merging of Taylor Advisors into HIP
as of 3/31/2026, the firm also engages in certain investment advisory services for institutional clients including
banks.
INVESTMENT ADVISORY - BANKS
The advisory service includes active management of client's fixed income portfolio. A quarterly investment analytics
report is provided as part of our service. All security purchases under the advisory service are supported with
purchase documentation. We frequently analyze and discuss the client's balance sheet before making investment
decisions. We gather detailed information about the investment portfolio, asset/liability profile, taxes, pledging, etc.
before making advisory decisions. The securities are purchased and sold on a competitive basis with at least two
brokers. We do not receive any commissions on the purchases/sales of the securities.
We can manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is
guided by the client's stated objectives as well as tax considerations.
Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors.
Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or
insurance company and will generally include advice regarding the following securities:
• United States governmental and agency securities
• Municipal securities
• Corporate debt securities (other than commercial paper)
types of
investments
involve certain additional degrees of risk,
Because some
they will only be
implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk,
liquidity, and suitability.
INVESTMENT CONSULTING SERVICES - BANKS
The Firm also offers investment consulting services to some of its institutional clients. In this instance, the fixed
income portfolio is managed by the client and transactions are executed by the client. We often gather detailed
information about the investment portfolio, asset/liability profile, taxes, pledging, etc. before making any consulting
decisions. A quarterly investment analytics report is provided as part of our service. The timing of the report may
not correspond to a calendar quarter. We may recommend brokers to the client based on past good execution and
product availability. Similarly, our investment consulting service is tailored to the specific objectives of each client
and based on the composition of the balance sheet.
Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors.
Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or
insurance company and will generally include advice regarding the following securities:
• United States governmental and agency securities
• Municipal securities
• Corporate debt securities (other than commercial paper)
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types of
investments
involve certain additional degrees of risk,
Because some
they will only be
implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk,
liquidity, and suitability.
BALANCE SHEET MANAGEMENT CONSULTING SERVICES - BANKS
The Firm also provides balance sheet management services to some of its clients. These services include
interpretation of A/L data, A/L policy review, A/L advice on deposit benchmarking, loan mix, liquidity management,
leverage strategies, hedging, and interest rate risk management. We hold discussions with management about the
financial institution's balance sheet and strategic direction.
PORTFOLIO MANAGEMENT
We provide portfolio management and retirement/financial planning services to individuals, high net worth
individuals, institutions, state and municipal entities, foundations, trusts and school districts.
For retail clients and high net worth individuals, we provide various portfolio management options that include
varying cash, equity, and fixed income, and alternative allocations. These strategies may include individual
securities, exchange traded funds, mutual funds, closed end funds and private funds, and other forms of
investments dependent on client objectives, risk tolerance, restrictions, and other parameters. We manage the
composition of several firm wide portfolio strategies internally while also providing more customized solutions for
clients as needed to meet client objectives. We provide regular portfolio reviews to ensure client objectives and risk
tolerance are appropriately considered and updated.
For corporate pension and profit-sharing plans, foundations and other institutional accounts we provide the same
services described above along with advising on investment policy statements and other issues that may be unique
to institutional accounts.
For state and municipal entities, we provide similar portfolio management services described above as well as local
policy reviews and other services unique to this client type. We have a special program entitled Managed Asset
Portfolio Program (“MAPP”) in which we advise on invested assets for municipal entities. This is generally a cash
management program subject to the client local policy as well as the Texas Public Funds Investment Act.
We also provide advisory services on defined contribution plans where we act as the advisor on plan investments
and aid the plan sponsor's investment committee in managing options for employees.
HUB Investment Partners investment adviser representatives may utilize a third-party asset manager (“TAMP”) to
allocate either all or certain segments of their clients’ investments. In most cases in which a TAMP is used, HUB
Investment Partners has discretion to determine which TAMP and/or which strategy will be used to manage the
client’s investment, including discretion to change those selections at any time. As a result, these client accounts
are included in our calculation of its regulatory assets under management.
All client types described above have the ability to impose restrictions on certain securities or types of securities.
RETIREMENT AND FINANCIAL PLANNING SERVICES
We are fiduciaries under the Investment Advisor Act of 1940 and when we provide investment advice to you
regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning
of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which
are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours.
At the same time, the way we make money creates some conflicts with your interests.
Our retirement and financial planning provides a detailed, written plan designed to assist our clients in achieving
their stated objectives and goals. Our plans address some or all of the following areas:
• Personal: A review of liquid assets, an analysis of debt and a review of personal savings and spending
patterns.
• Risk Management: An evaluation of the adequacy of a client’s risk management techniques (with respect
•
to common risks, such as premature death, disability, illness, property loss and/or damage, liability, long
term care and unemployment).
‐
Investments: A review of a client’s investments to ensure they are consistent with the client’s risk tolerance
and appropriate in light of the client’s objectives and goals (e.g., time horizon, liquidity and marketability,
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rate of return and risk).
• Tax: Assistance in selecting appropriate investments based on tax efficiency.
• Retirement Planning: An evaluation of a client’s current financial situation and retirement plans/needs and
the appropriateness of current investments.
When providing retirement and financial plans, we make general and/or specific product and strategy
recommendations. If we make such recommendations, they will be tailored to meet the objectives, goals and risk
tolerance of that specific client. The client is under no obligation to use our services to implement such
recommendations.
HUB ADVISOR CONNECT
HUB Advisor Connect provides basic financial planning and wealth management services to individuals, including
active and terminated retirement plan participants, as well as individuals who may not otherwise have access to
these services. Clients may access HUB Advisor Connect directly through the FinPath platform or through internal
referrals from HUB affiliates. HUB Investment Partners' investment adviser representatives provide these services,
including education related to distributions for terminated retirement plan participants.
SUB ADVISOR RELATIONSHIPS
HUB Investment Partners may act as a Sub-Advisor to affiliate Registered Investment Advisor(s) to provide,
amongst other things, discretionary model portfolio design and rebalancing services. The affiliate Registered
Investment Advisor(s) will compensate HUB Investment Partners from its fee and does not charge a separate fee
for using HUB Investment Partners. Rather, the affiliate Registered Investment Advisor(s) reduce its compensation
by compensating HUB Investment Partners through its agreed upon compensation and fee billing structure. In its
capacity as Sub-Advisor, HUB Investment Partners has full discretionary authority over the client’s assets and earns
related compensation. The affiliate RIA selects HUB Investment Partners as Sub-Advisor for a client account only
when it is deemed to be in the client’s best interest.
CLIENT ASSETS UNDER MANAGEMENT
HUB Investment Partners provides investment advisory and management services to clients. As of December 31,
2025, HUB Investment Partners reflects $11,878,526,853 in regulatory assets under management.
ITEM 5 – FEES AND COMPENSATION
RETAIL INVESTMENT ADVISORY ACCOUNTS
We receive an asset management fee based on the value of the assets of each account for which we provide
investment advisory services. The asset management fee may vary based on the nature, size and complexity of
each client’s account and is negotiable.
The asset management fee does not include brokerage commissions, ticket charges, interest charges, exchange
fees, wire transfer fees, or other costs or fees associated with securities transactions or those required by law. As
the client, you may incur charges imposed by other investment managers or sub-advisors, custodial fees, deferred
sales charges, and other transactional fees. Mutual funds and exchange traded funds also charge internal
management fees, which are disclosed in the fund’s prospectus. Such charges, fees and commissions are exclusive
of and in addition to our asset management fee, and we do not receive any portion of these commissions, fees, and
costs.
Item 12 below further describes the factors that we consider in selecting or recommending broker/dealers for client
transactions and determining the reasonableness of their compensation (e.g., commissions).
ASSET MANAGEMENT FEES
Our standard annual asset management fee schedule for individuals is as follows:
Annual Management Fee
Net Assets
$0.00 - $99,999.99
$100,000 - $999,999.99
$1,000,000 - $2,999,999.99
$3,000,000 - $6,999,999.99
$7,000,000 - $9,999,999.99
1.50%
1.25%
1.00%
0.75%
0.50%
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$10,000,000 and over
Negotiated
Asset management fees are typically payable in advance for the following calendar quarter,
unless another period is agreed to. The fees are based on the net asset value of the account on the last day of the
prior period and are a proportionate share of the annual management fee. Typically, asset management fees are
payment arrangements (i.e., payment by check) may
deducted by the custodian of your account(s). Alternative fee
be made. Asset management fees are prorated for each capital contribution and withdrawal.
‐
If you open or terminate an account during a calendar quarter, you will be charged a prorated asset management
fee. This is based on the number of days in the period. It is calculated on the first day the account is funded based
on the number of days left in the period. Upon prior thirty (30) day notification of termination of any account, any
prepaid, unearned asset management fees, calculated in the same manner, will be promptly refunded, and any
earned, unpaid fees will be due and payable. The procedure set forth in this paragraph also applies if the specified
period is something other than quarterly (i.e., monthly or semiannually).
MAPP FEES
HUB Investment Partners receives a management fee for services provided under the Managed Asset Portfolio
Program. The management fee may be a flat fee or AUM based fee billed in monthly, quarterly, or annual
installments and prorated accordingly. If the fee is AUM based, it is typically 0.1% (10 basis points) for advisory
relationships <$50.0 million. Accounts over $50.0 million and on an AUM based fee agreement are charged under
the following schedule:
Net Assets
$0.00 - $50,000,000
$50,000,000.01 - $100,000,000
$100,000,000.01 - $150,000,000
$150,000,000.01 and over
Annual Management Fee
0.10%
0.08%
0.06%
0.05%
We may negotiate the Management Fees based on the size, duration and number of the municipality’s account(s).
MAPP also has a reporting only component that may charge a $1,000-$1,500 flat fee per quarter, depending on the
complexity of reporting requirements. For more information on Performance Fees, see Item 6 of this Brochure.
RETIREMENT AND FINANCIAL PLANNING FEES
Retirement/financial planning services fees may be an hourly rate, a flat fee and/or a percentage of the assets under
management. Retirement/financial planning service fees vary based on the nature, size and complexity of each
client’s account and are negotiable. All fees are agreed to in advance of us entering into an agreement with any
client. Such fees are payable only after the plan has been delivered to the client; however, alternative fee
payment
arrangements may be made.
‐
‐
An agreement for retirement/financial planning services may usually be terminated, for any reason, upon written
notice by either party. Since, however, these are often longer
term contracts negotiated with employers and other
institutions, these contracts may have more restrictive termination provisions. If cancellation occurs, any unearned
fees will be refunded promptly to the client, and any unpaid fees become due and payable as of the date of the
termination.
THIRD PARTY ASSET MANAGER FEES
If the investment adviser representative utilizes a TAMP to manage all or any part of the client’s account, the client
will likely be required to enter into a separate agreement with the TAMP. If the TAMP agreement governs the terms
under which the advisory fee will be collected, the TAMPs’ investment management agreement will only specify the
fee that will be deducted by the TAMP. Specifically, if the TAMP collects a unified fee, it will forward HUB Investment
Partners’ portion of the fee as specified on TAMPs’ investment management agreement with the client to HUB
Investment Partners. Alternatively, HUB Investment Partners may deduct the management fee from the client’s
account and forward the TAMP’s portion to the TAMP.
SUB ADVISORY FEES
HUB Investment Partners offers Sub-Advisor investment management services to an affiliated registered
investment adviser and earns related compensation. Under the Sub-Advisor relationship, the affiliate invoices the
client, collects the fee and compensates HUB Investment Partners 15 bps of the fee on a quarterly basis. There is
no additional fee charged to the client to utilize HUB Investment Partners as a Sub-Advisor.
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INVESTMENT ADVISORY SERVICES - BANKS
The Firm has some clients with fees as a percentage of assets and some with flat fees. All investment advisory
contracts can be terminated with a 30-day notice, and any part of the fee that is not earned by HIP is not billed or
is refunded to the client. Our annual fees for Investment Supervisory Services are based upon a percentage of
assets under management. The fees will vary based on portfolio size and mix and the type of services performed.
INVESTMENT CONSULTING SERVICES - BANKS
The Firm charges flat fees for investment consulting services. All investment consulting contracts can be terminated
with a 30-day notice, and any part of the fee that is not earned by HIP is not billed or is refunded to the client.
BALANCE SHEET MANAGEMENT CONSULTING SERVICES - BANKS
The Firm charges flat fees for balance sheet management consulting services. All balance sheet management
consulting contracts can be terminated with a 30-day notice.
GENERAL INFORMATION
Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either party, for
any reason upon receipt of 30 days written notice. Upon termination of any account, any prepaid, unearned fees
will be promptly refunded.
Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and
expenses charged by custodians and imposed by broker dealers, including, but not limited to, any transaction
charges imposed by a broker dealer with which an independent investment manager effects transactions for the
client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional
information.
ITEM 6 – PERFORMANCE BASED FEES AND SIDE BY SIDE MANAGEMENT
based fee
HUB Investment Partners has no trading portfolios for individual retail clients that charge a performance
(fees based on a share of capital gains on or capital appreciation of the assets of a client).
‐
ITEM 7 – TYPES OF CLIENTS
We provide portfolio management and retirement/financial planning services to individuals, high net worth
individuals, corporate pension and profit
sharing plans, defined contribution plans, institutions, school districts, state
and municipal entities, foundations, trusts, all considered our advisory clients (“Client” or “Clients”).
‐
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
ANALYSIS METHODS FOR INDIVIDUAL CLIENT MANAGED ACCOUNTS
We construct client portfolios using a combination that consist primarily of individual stocks, bonds, ETFs, closed-
end funds, mutual funds, and alternative investments (including tender offer funds, interval funds, BDCs, REITs,
and limited partnerships). We manage assets through direct securities purchases and allocations to third party
investment managers via funds, other pooled investment vehicles, and separately managed accounts. Each client’s
asset allocation is tailored to their specific objectives and circumstances.
Our investment approach begins with a comprehensive understanding of each client’s goals, risk tolerance, time
horizon, and income needs. We emphasize a long-term strategy, though we may adopt a short-term approach when
circumstances change.
We use both active and passive management strategies. Our investment team, guided by the Investment
Committee, conducts both quantitative and qualitative reviews to identify robust strategies within each asset class.
Investment manager screening may include reviews of performance, consistency, management structure,
experience, scale, and resources.
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ANALYSIS METHODS FOR INSTITUTIONAL ACCOUNTS
Institutional accounts, where we serve as a non
discretionary advisor, are reviewed and evaluated quarterly. The
securities and their performance are compared to the institution’s investment policy statement. The evaluation
process includes the following:
• Comparing the rate of return for each security (net of investment manager fees and fund expenses) to its
benchmark (peer group universe);
• Determining the progress made in achieving the goals in the investment policy statement;
• Noting deviations from the investment policy;
• Reviewing market and economic conditions;
• Making projections for the coming quarter’s market and economic conditions;
• Preparing recommendations for each fund - hold, remove, or place on the watch list; and
• Recommending new funds to add, if any.
If, based upon the evaluation, we believe that changes are necessary, we take those recommendations to the
institution’s investment committee to vote on the changes. Changes may be to remove a security, to place it on a
watch list (or remove from the watch list) or to add a security.
RISK OF LOSS
Clients should understand that all investment strategies and the investments made when implementing those
investment strategies involve risk of loss and clients should be prepared to bear the loss of assets invested. The
investment performance and the success of any investment strategy or particular investment can never be predicted
or guaranteed, and the value of a client’s investments fluctuates due to market conditions and other factors. The
investment decisions made, and the actions taken for client accounts are subject to various market, liquidity,
currency, economic and political risks, and will not necessarily be profitable. Past performance of client accounts is
not indicative of future performance.
This Brochure does not include every potential risk associated with an investment strategy, or all of the risks
applicable to a particular client account. Rather, it is a general description of the nature and risks of the strategies
and securities and other financial instruments in which client accounts may invest. The following risks may apply to
strategies managed by us:
• Asset Allocation and Rebalancing Risk – The risk that a client accounts may be out of balance with the
target allocation. Any rebalancing of such assets by us may be limited by several factors and, even if
achieved, may have an adverse effect on the performance of the client’s account(s) assets. Asset allocation
strategies do not assure profit or diversification and do not protect against loss.
• Asset Class Risk – Securities in a portfolio may underperform in comparison to the general securities
markets, a particular securities market, or other asset classes.
• Concentration Risk – The increased risk of loss associated with not having a diversified portfolio (i.e., client
accounts concentrated in a geographic region, industry sector or issuer are more likely to experience
greater loss due to an adverse economic, business or political development affecting the region, sector or
issuer than an account that is diversified and therefore has less overall exposure to a particular region,
sector or issuer).
• Credit/Default Risk – Debt issuers and other counterparties of fixed income securities or instruments may
default on their obligation to pay interest, repay principal, or make a margin payment, or default on any
other obligation. Additionally, the credit quality of securities or instruments may deteriorate (e.g., be
downgraded by ratings agencies), which may impair a security’s or instruments liquidity and decrease its
value.
• Currency Risk – Currencies may be purchased or sold for a client’s portfolio through the use of forward
contracts or other instruments. A client’s portfolio that seeks to trade in foreign currencies may have limited
access to certain currency markets due to a variety of factors including government regulations, adverse
tax treatment, exchange controls, and currency convertibility issues. A client’s portfolio may hold
investments denominated in currencies other than the currency in which the client’s portfolio is
denominated. Currency exchange rates can be volatile, particularly during times of political or economic
unrest or as a result of actions taken by central banks. A change in the exchange rates may produce
significant losses to a client’s portfolio.
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• Cyber Security Risk – With the increased use of technologies such as the Internet to conduct business, a
portfolio is susceptible to operational, information security and related risks. In general, cyber incidents can
result from deliberate attacks or unintentional events and are not limited to, gaining unauthorized access to
digital systems, and misappropriating assets or sensitive information, corrupting data, or causing
operational disruption, including the denial-of-service attacks on websites. Cyber security failures or
breaches by a third party service provider and the issuers of securities in which the portfolio invests, have
the ability to cause disruptions and impact business operations, potentially resulting in financial losses, the
inability to transact business, violations of applicable privacy and other laws, regulatory fines, penalties,
reputational damage, reimbursement or other compensation costs, and/or additional compliance costs,
including the cost to prevent cyber incidents.
• Data Processes Incorporating Artificial Intelligence Risk – We use artificial intelligence (“AI”) tools to assist
with data gathering and consolidation. While these tools improve efficiency, they present risks including
data accuracy, bias and limitations of algorithms selecting source data, increased exposure to data
breaches due to use of external platforms, and changes to the standards and regulations of AI platforms.
We do not use AI to make investment recommendations or decisions. We apply human oversight, data
validation checks and security measures to mitigate these risks, but they cannot be eliminated entirely.
• Emerging Markets Risk – Investments in emerging markets may be subject to a greater risk of loss than
investments in more developed markets, as they are more likely to experience inflation risk, political turmoil
and rapid changes in economic conditions. Investing in the securities of emerging markets involves certain
considerations not typically associated with investing in more developed markets, including but not limited
to, the small size of such securities markets and the low volume of trading (possibly resulting in potential
lack of liquidity and in price volatility), political risks of emerging markets which may include unstable
governments, government intervention in securities or currency markets, nationalization, restrictions on
foreign ownership and investment, laws preventing repatriation of assets and legal systems that do not
adequately protect property rights. Further, emerging markets may be adversely affected by changes to the
economic health of certain key trading partners, such as the U.S., regional and global conflicts and terrorism
and war. Emerging markets often have less uniformity in accounting and reporting requirements, unreliable
securities valuation and greater risk associated with custody of securities
• Environmental Risks – The risk of loss as a result of statutes, rules and regulations relating to environmental
protection negatively impacting the business of the issuers.
• Equity Risks – The market price of securities owned by clients may go up or down, sometimes rapidly or
unpredictably. The equity securities in clients’ portfolios may decline in value due to factors affecting equity
securities markets generally or the energy sector. The values of equity securities may decline due to general
market conditions which are not specifically related to a particular company, such as real or perceived
adverse economic conditions, changes in the general outlook for corporate earnings, changes in interest
or currency rates or adverse investor sentiment generally. They may also decline due to factors which affect
a particular industry or industries, including the basic minerals sector, such as labor shortages or increased
production costs and competitive conditions within an industry. Other risks of investing globally in equity
securities may include changes in currency exchange rates, exchange control regulations, expropriation of
assets or nationalization, imposition of withholding taxes on dividend or interest payments, and difficulty in
obtaining and enforcing judgments against non-U.S. entities. In addition, securities which we believe are
fundamentally undervalued or incorrectly valued may not ultimately be valued in the capital markets at
prices and/or within the time frame we anticipate. As a result, clients may lose all or substantially all of their
investments in any particular instance.
• Fixed Income Securities – We may invest client assets in bonds or other fixed income securities of issuers
including, without limitation, bonds, notes and debentures issued by corporations, debt securities and
commercial paper. Fixed income securities pay fixed, variable or floating rates of interest. The value of fixed
income securities in which we invest will change in response to fluctuations in interest rates. In
addition, the value of certain fixed income securities can fluctuate in response to perceptions of
creditworthiness, political stability or soundness of economic policies. Fixed income securities are
subject to the risk of the issuer’s inability to meet principal and interest payments on its obligations
(i.e., credit risk) and are subject to price volatility due to such factors as interest rate sensitivity,
market perception of the creditworthiness of the issuer and general market liquidity (i.e., market
risk).
• General Economic and Market Conditions – The success of our activities is affected by general economic
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and market conditions, such as changes in interest rates, availability of credit and debt-related issues,
inflation rates, economic uncertainty, changes in laws (including laws relating to taxation of client
investments), trade barriers, unemployment rates, release of economic data, currency exchange controls
and national and international political circumstances (including wars, terrorist acts, pandemics, natural
disasters, security operations, the European debt crisis or the U.S. budget negotiations). These factors may
affect the level and volatility of securities prices and the liquidity of client investments. Volatility and/or
illiquidity could impair profitability or result in losses. Clients could incur material losses even if we react
quickly to difficult market or economic conditions, and there can be no assurance that clients will not suffer
material losses and other adverse effects from broad and rapid changes in economic and market conditions
in the future. Clients should realize that markets for the financial instruments in which we invest client assets
can correlate strongly with each other at times or in ways that are difficult for us to predict. Even a well-
analyzed approach may not protect clients from significant losses under certain market conditions.
• Highly Volatile Markets – The prices of financial instruments in which we may invest client assets can be
highly volatile. Price movements of the financial instruments in which client assets are invested are
influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal,
monetary and exchange control programs and policies of governments, and national and international
political and economic events and policies. Clients are subject to the risk of failure of any of the exchanges
on which their positions trade or of their clearinghouses. In addition, governments from time to time
intervene in certain markets, directly and by regulation, particularly in currencies, futures and options. Such
intervention is often intended to directly influence prices and may, together with other factors, cause some
or all of these markets to move rapidly in the same direction. The effect of such intervention is often
heightened by a group of governments acting in concert.
•
Illiquid Investments – Under certain market conditions, such as during volatile markets or when trading in
an interest or market is otherwise impaired, the liquidity of client investments may be reduced. In addition,
a client may from time to time hold large positions with respect to a specific type of investment, which may
reduce the client’s liquidity. During such times, the client may be unable to dispose of certain assets, which
would adversely affect the client’s ability to rebalance its portfolio or to meet withdrawal requests. In
addition, such circumstances may force the client to dispose of assets at reduced prices, thereby adversely
affecting the client’s performance. If there are other market participants seeking to dispose of similar assets
at the same time, the client may be unable to sell such assets or prevent losses relating to such assets.
Furthermore, if a client incurs substantial trading losses, the need for liquidity could rise sharply while its
access to liquidity could be impaired. In conjunction with a market downturn, the client’s counterparties
could incur losses of their own, thereby weakening their financial condition and increasing the client’s credit
risk to them. Many non-U.S. financial markets are not as developed or as efficient as those in the U.S., and
as a result, liquidity may be reduced for client investments.
•
Income Risk – A client’s portfolio income may decline when interest rates decrease. During periods of falling
interest rates an issuer may be able to repay principal prior to the security’s maturity (“prepayment”),
causing the client’s portfolio to have to reinvest in securities with a lower yield, resulting in a decline in the
client’s portfolio income.
•
Interest Rate Risk – When interest rates increase, fixed income securities or instruments will generally
decline in value. Long-term fixed income securities or instruments will normally have more price volatility
because of this risk than short-term fixed income securities or instruments.
•
Investment and Trading Risks Generally – All investments risk the loss of capital. No guarantee or
representation is or can be made that our investment program will be successful. Our investment program
may involve, without limitation, risks associated with limited diversification, short-selling, commodity interest
trading, equity risks, distressed issuers, interest rates, volatility, tracking risks in hedged positions, security
borrowing risks in short sales, credit deterioration or default risks, systems risks and other risks inherent in
activities. Certain investment techniques may, in certain circumstances, substantially increase the impact
of adverse market movements to which our clients may be subject. In addition, client investments may be
materially affected by conditions in the financial markets and U.S. and worldwide economic conditions. Our
methods of minimizing such risks may not accurately predict future risk exposures. Risk management
techniques are based in part on the observation of historical market behavior, which may not predict market
divergences that are larger than historical indicators. Also, information used to manage risks may not be
accurate, complete or current, and such information may be misinterpreted.
•
Investment Style Risk – Different investment styles tend to shift in and out of favor depending upon market
and economic conditions and investor sentiment. Client portfolios may outperform or underperform other
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client portfolios that invest in similar asset classes but employ different investment styles.
• Large-Cap Company Risk – Larger, more established companies may be unable to attain the high growth
rates of successful, smaller companies during periods of economic expansion.
• Leveraging Risk – Certain client transactions, including futures contracts and short positions in financial
instruments, may give rise to a form of leverage. Leverage can magnify the effects of changes in the value
of the client’s investments and make the client’s portfolio more volatile. Leverage creates a risk of loss of
value on a larger pool of assets than the client would otherwise have had, potentially resulting in the loss
of all assets. The client may also have to sell assets at inopportune times to satisfy its obligations in
connection with such transactions.
• Limited Diversification and Risk Management Failures – At any given time, client assets may not be
diversified to any material extent and, as a result, clients could experience significant losses if general
economic conditions, and, in particular, those relevant to the issuers whose securities are owned by our
clients (i.e., REIT-related securities), decline. In addition, client portfolios could become significantly
concentrated in a limited number of issuers, types of financial instruments, industries, strategies, countries,
or geographic regions, and any such concentration of risk may increase losses suffered by clients. This
limited diversity could expose clients to losses disproportionate to market movements in general. Other
investment funds pursue similar strategies, which creates the risk that many funds may be forced to
liquidate positions at the same time, reducing liquidity, increasing volatility, and exacerbating losses.
Although we attempt to identify, monitor, and manage significant risks, these efforts do not take all risks
into account and there can be no assurance that these efforts will be effective. Many risk management
techniques are based on observed historical market behavior, but future market behavior may be entirely
different. Any inadequacy or failure in our risk management efforts could result in material losses for clients.
• Liquidity Risk – The risk that a client may not be able to monetize investments and may have to hold to
maturity or may also only be able to obtain a lower price for investments either because those investments
have become less liquid or illiquid in response to market developments or adverse investor perceptions.
Investments that are illiquid or that trade in lower volumes may be more difficult to value.
• Low Trading Volume Risk – The risk that a client may not be able to monetize his/her investment or will
have to do so at a loss as a result of generally lower trading volumes of the securities compared to other
types of securities or financial instruments.
• Management and Strategy Risk – The value of a client’s investment depends on our judgment about the
quality, relative yield, value, or market trends affecting a particular security, industry, sector or region, which
may prove to be incorrect. Investment strategies employed by us in selecting investments for a client may
not result in an increase in the value of the client’s investment or in overall performance equal to other
investments.
• Municipal Securities Risk – Municipal securities can be significantly affected by political or economic
changes, as well as uncertainties in the municipal market related to taxation, changes in interest rates,
relative lack of information about certain issuers of municipal securities, legislative changes, or the rights of
municipal security holders. Municipal securities backed by current or anticipated revenues from a specific
project or specific assets can be negatively affected by the inability to collect revenues for the project or
from the assets.
• Non-U.S. Investments – We might periodically invest client assets in financial instruments of non-U.S.
corporations and governments. Investing in the financial instruments of companies (and, from time to time,
governments) outside of the United States involves certain considerations not usually associated with
investing in financial instruments of U.S. companies or the U.S. government, including political and
economic considerations, such as greater risks of expropriation, nationalization, confiscatory taxation,
imposition of withholding or other taxes on interest, dividends, capital gains or other income, limitations on
the removal of assets and general social, political and economic instability; the relatively small size of the
securities markets in such countries and the low volume of trading, resulting in potential lack of liquidity and
in price volatility; the evolving and unsophisticated laws and regulations applicable to the securities and
financial services industries of certain countries; fluctuations in the rate of exchange between currencies
and costs associated with currency conversion; and certain government policies that may restrict
investment opportunities. In addition, accounting and financial reporting standards that prevail outside of
the U.S. generally are not as high as U.S. standards and, consequently, less information is typically
available concerning companies located outside of the U.S. than for those located in the U.S. As a result,
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we may be unable to structure client transactions to achieve the intended results or to mitigate all risks
associated with such markets. It may also be difficult to enforce our clients’ rights in such markets. For
example, financial instruments traded on non-U.S. exchanges and the non-U.S. persons that trade these
instruments are not subject to the jurisdiction of the SEC or the CFTC or the securities and commodities
laws and regulations of the U.S. Accordingly, the protections accorded to clients under such laws and
regulations are unavailable for transactions on foreign exchanges and with foreign counterparties.
• Small-Cap and Mid-Cap Company Risk – The securities of small-capitalization and mid-capitalization
companies may be subject to more abrupt or erratic market movements and may have lower trading
volumes or more erratic trading than securities of larger, more established companies or market averages
in general. In addition, such companies typically are more likely to be adversely affected than large
capitalization companies by changes in earning results, business prospects, investor expectations or poor
economic or market conditions.
• Terrorist Attacks, War and Natural Disasters – Terrorist activities, anti-terrorist efforts, armed conflicts
involving the United States or its interests abroad and natural disasters may adversely affect the United
States, its financial markets and global economies and markets and could prevent us and our clients from
meeting their respective investment objectives and other obligations. The potential for future terrorist
attacks, the national and international response to terrorist attacks, acts of war or hostility, domestic
insurrections, civil unrest, natural disasters and other recent events such as pandemics, epidemics, and
other outbreaks of infectious diseases, have created many economic and political uncertainties, which may
adversely affect the United States and world financial markets and our clients for the short or long-term in
ways that cannot presently be predicted.
• Underperformance Risk – The risk that the strategy may underperform the underlying investments due to
reasons such as the capped feature of one or more investments and the fact that such structured
investments do not receive dividends.
ITEM 9 – DISCIPLINARY INFORMATION
Registered investment advisors are required to disclose material facts regarding any legal or disciplinary events
that would be material to your evaluation of HUB Investment Partners or the integrity of our management. None of
our management team have disciplinary information to disclose.
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
HUB Investment Partners is owned by RPW Holdings, LLC, a HUB International company (“HUB”). Affiliated
companies owned by HUB (please see below) include registered investment advisers which are only engaged in
investment advisory, consulting and other financial services. HUB Investment Partners also may offer insurance
services through HUB International, which may result in additional compensation. Clients are not required to
purchase any insurance-related services.
TCG CONSULTING
TCG Consulting Services, LLC (“TCG Consulting”) provides consulting services for a fee to institutional clients (e.g.
school districts, municipalities, etc.), including analyzing a client’s needs, assisting in the preparation of Request for
Proposals for insurance and investment products and assisting in the evaluation of responses as well as in providing
evaluation services with respect to existing programs.
Additionally, TCG Consulting provides consulting services to small businesses and/or family-owned enterprises and
employers and employees with respect to the negotiation and terms of employment agreements. TCG Consulting
provides consulting services to some of the clients for which HUB Investment Partners serves as an investment
adviser. HUB Investment Partners and TCG Consulting recommend the other company’s services, as appropriate,
to meet the needs of clients. The relationship or arrangement may create a conflict of interest with clients as HUB
Investment Partners may receive compensation for such referral, However, no client is under any obligation to
engage TCG Consulting.
TCG ADMINISTRATORS
party administrative services to clients. HUB Investment Partners recommends
TCG Administrators provides third
TCG Administrators’ services to clients. Our recommendation of TCG Administrators’ services is in those situations
‐
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where we believe that it is appropriate and, in the client’s best interest to use those services. TCG Administrators is
only administrator and does not sell any investment products. TCG Administrators has engaged its auditor to
a fee
perform an internal controls report (SSAE 18) that complies with Rule 206(4)-2(a)(6)(A) which contains an opinion
of an independent public accountant as to the control objectives relating to custodial services, including the
safeguarding of funds and securities held by either HUB Investment Partners or a related person on behalf of
advisory clients. The relationship or arrangement may create a conflict of interest with clients as HUB Investment
Partners may receive compensation for such referral, however, no client is under any obligation to engage TCG
Administrators.
RPW SOLUTIONS
RPW Solutions is an affiliate of HUB Investment Partners. RPW Solutions offers FinPath, a financial wellness tool
for individuals, which includes access to a Financial Coach who can provide personalized financial coaching to
individuals. As part of the coaching relationship established through FinPath, the Financial Coach may refer the
individual to HIP via HUB Advisor Connect for investment advisory services and will earn related compensation if
the individual elects to engage HUB Advisor Connect for investment advisory services. The compensation paid to
the Financial Coach does not increase the fees paid by the client; however, it presents a conflict of interest in that
the Financial Coach is financially incentivized to make a referral based on the related compensation and . RPW
Solutions is an affiliate of HUB Investment Partners. HIP will receive additional compensation due to increased
assets under management.
SUB ADVISORY SERVICES
HUB Investment Partners offers management services to an affiliated registered investment adviser, providing
discretionary model portfolio design and rebalancing to affiliate RIA clients. There is no additional fee charged to
the client to utilize HUB Investment Partners as a Sub-Advisor.
AFFILIATED REGISTERED INVESTMENT ADVISERS
In addition, HUB Investment Partners is under common ownership with the following HUB owned SEC registered
investment advisors: HUB International Investment Services, Inc., RPA Financial, LLC, and Global Retirement
Partners, LLC.
AFFILIATED BROKER DEALER
Certain of our IARs hold securities licenses with HUB International Investment Services, LLC (“HIIS”), a FINRA
registered broker-dealer, under common control of HUB. HIIS itself does not maintain any securities brokerage
clients and is limited in business scope to facilitating revenue sharing of transactions executed through third-party
broker-dealers and services provided through third-party registered investment advisers. HIIS does not sell broker-
dealer services or securities products.
HESSLER LAW D/B/A/ FULL SUITE WEALTH MANAGEMENT
HUB Investment Partners maintains an arrangement with Hessler Law, an unaffiliated law firm, whereby HUB
Investment Partners refers clients to Hessler Law as deemed appropriate. HUB Investment Partners does not
receive compensation for such referral, and no client is under any obligation to engage Hessler Law. In certain
limited circumstances, unless the matter is specialized and highly complex, HUB Investment Partners may reduce
its fee charged to clients in the amount equal to the Hessler Law fee.
UPTIQ
HUB Investment Partners has entered into a relationship with UPTIQ, an unaffiliated internet-based lending platform
providing a large network of lenders. UPTIQ has the ability to assist private wealth clients of HUB Investment
Partners with a variety of different types of personal and business loans (i.e., mortgage, home equity, auto,
commercial, working capital, etc.). UPTIQ’s platform seeks to match the client with those lenders who can meet the
client’s borrowing needs and to help facilitate the loan application and fulfillment process once a lender is selected.
UPTIQ is compensated only by the lender and HUB Investment Partners does not receive any compensation in
connection with client use of the UPTIQ platform. However, a conflict of interest exists in that HUB Investment
Partners has incentive to introduce the client(s) to UPTIQ as an alternative to liquidating investment assets to meet
personal or business liquidity needs, which could allow HUB Investment Partners to retain assets under
management and earn related advisory fees. . Only clients that express a desire for such loan services will be
referred to UPTIQ and HUB Investment Partners obtain client consent before sharing any client information with
UPTIQ. No client is under any obligation whatsoever to utilize UPTIQ’s services. There can be no assurance that
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the lending terms obtained via the UPTIQ platform will be more favorable than those available from non-platform
lenders. The client remains free to consider/evaluate/utilize other lenders and sources.
ITEM 11 – CODE OF ETHICS PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
AND PERSONAL TRADING
We have adopted a Code of Ethics for all supervised persons of the firm describing our standard of business conduct
and fiduciary duty to our clients. The Code of Ethics includes provisions relating to the confidentiality of client
information and a prohibition on insider trading, among other things. All supervised persons must acknowledge the
terms of the Code of Ethics annually, or as amended. You may request a copy of our Code of Ethics by contacting
our Chief Compliance Officer listed on the cover of this Brochure.
PERSONAL SECURITIES TRANSACTIONS
We anticipate that, in appropriate circumstances and consistent with clients’ investment objectives, we will
recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which we, our
affiliates and/or our clients, directly or indirectly, have a position of interest. Our employees and persons associated
with us are required to follow our Code of Ethics. Subject to satisfying this policy and applicable laws, officers,
directors and employees of HUB Investment Partners and its affiliates may trade for their own accounts in securities
which are recommended to and/or purchased for our clients.
We designed the Code of Ethics to ensure that the personal securities transactions, activities and interests of our
employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing
such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain
classes of securities have been designated as exempt transactions, based upon a determination that these would
not materially interfere with the best interest of our clients. In addition, the Code requires pre
clearance of many
transactions, and limits trading in close proximity to client trading activity.
‐
Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same
securities as clients, there is a possibility that employees might benefit from market activity by a client in a security
held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably
prevent conflicts of interest between us and our clients.
ITEM 12 – BROKERAGE PRACTICES
We do not receive any soft dollar benefits from broker/dealers for placing trades through such broker/dealer. We
do not have any directed brokerage agreements. We recommend broker/dealers with whom we have an approved
selling agreement and who, in our opinion, are able to provide the best price and execution. The Firm may evaluate
broker/dealers on a variety of factors: the ability to achieve prompt and reliable executions; the executed trades are
done at favorable prices; the operational efficiency with which the broker/dealer executes the transactions; the
financial strength, integrity and stability of the broker/dealer; and the competitiveness of commission rates in
comparison with other brokers satisfying our other selection criteria.
TRADE ORDER PRACTICES
Certain affiliated accounts may trade in the same securities with client accounts on an aggregated basis when
consistent with our 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. We 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.
AGGREGATING TRADES
We do aggregate trades when possible. This is primarily done on large model changes where we need clients to all
receive the same pricing. It is done on a best-efforts basis from day to day for individual account rebalances.
However, it is not always completed due to the nature of the trading desk and advisors sending in client trades at
various times and in different models and securities.
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CROSS SECURITIES TRANSACTIONS
It is our policy that the Firm will not affect any principal or agency cross securities transactions for client accounts,
unless pre-approved per our compliance manual. We will also not make cross trades between client accounts,
unless pre-approved per our compliance manual. Principal transactions are generally defined as transactions where
an advisor, 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 advisor in relation to a transaction in which the investment
advisor, or any person controlled by or under common control with the investment advisor, 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 advisor is dually registered as a broker/dealer or has an affiliated broker/dealer. HUB Investment Partners
does not have such arrangement.
BLOCK TRADING POLICY
The majority of trades implemented by us are completed on an individual basis. In cases when we need to
implement buys or sells of the same security for numerous accounts, we may elect to purchase or sell such
securities at approximately the same time as a block trade. This process is also referred to as aggregating orders
and batch trading and is used by our Firm when we believe such action may prove advantageous to clients. If we
aggregate client orders, allocating securities among client accounts is done on a fair and equitable basis. The
process of aggregating client orders is done to achieve better execution across client accounts. We may also do it
to achieve more favorable commission rates or allocate orders among clients more equitably to avoid differences
in prices and transaction fees or other transaction costs that might be obtained when orders are placed
independently. We use the pro rata allocation method for transaction allocation. Under this procedure, pro rata trade
allocation means an allocation of the trade is issued among applicable advisory clients in amounts that are
proportional to the participating advisory client’s intended investment. We will calculate the pro rata share of each
transaction included in a block order and assign the appropriate number of shares for each allocated transaction
executed for the client’s account. This process is executed on a per-custodian basis. For example, all accounts held
at Charles Schwab by us would receive the average price of all shares block traded at Charles Schwab by us. It is
possible that clients at different custodians receive different average prices for block trades executed on the same
trading day. If we determine to aggregate client orders for the purchase or sale of securities, including securities in
which our employees may invest. In that case, we will do so in accordance with the parameters outlined in the SEC
No-Action Letter, SMC Capital, Inc. Neither we nor our employees receive any additional compensation because of
block trades.
RESEARCH AND OTHER SOFT-DOLLAR BENEFITS
While HUB Investment Partners has no formal soft dollars program in which soft dollars are used to pay for third
party services, HUB Investment Partners may receive research, products, or other services from custodians and
broker-dealers in connection with client securities transactions (“soft dollar benefits”).
There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s
transactions paid for it, and HUB Investment Partners does not seek to allocate benefits to client accounts
proportionate to any soft dollar credits generated by the accounts. HUB Investment Partners benefits by not having
to produce or pay for the research, products or services, and HUB Investment Partners will have an incentive to
recommend a broker-dealer based on receiving research or services. Clients should be aware that HUB Investment
Partners’ acceptance of soft dollar benefits may result in higher commissions charged to the client.
Many broker/dealers offer research services. This is an additional component in our choosing with which
broker/dealers to enter into a selling arrangement. We look at the quality, comprehensiveness and frequency of
such research services to determine who we select as broker/dealers for our managed account program. The
research services that these broker/dealers provide supplements the other tools that we use to analyze the
securities that we recommend.
Charles Schwab & Co., Inc. (“Schwab") offers certain services to independent investment advisors services which
includes custody of securities, trade execution, clearance, and settlement of transactions. We receive some benefits
from Schwab by using them as the custodian.
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ITEM 13 – REVIEW OF ACCOUNTS
As a fiduciary, we are required to periodically review client accounts. Such accounts are periodically reviewed by
the Investment Advisor Representative Supervisor and/or designee. If we believe that an allocation change is
appropriate based on its account review, we will promptly advise the client and make recommendations to effect
such changes. To supplement the reports from the custodian, we generally provide clients with a quarterly review of
their accounts, unless the client requests reviews on a more frequent basis.
We review discretionary accounts quarterly. Written quarterly performance reports are provided to each client. The
reports list the individual holdings, sector weightings, and quarterly performance. Benchmark comparisons are
provided. Additional reports may include:
Income & Expense Reports
•
• Performance History
• Unrealized Gains and Losses
• Transaction Reports
• Security
• Losses
• Appraisal
INDIVIDUAL CLIENT MANAGED ACCOUNTS
Managed accounts are reviewed on a regular basis by appropriate supervisory personnel. We review and evaluate
each account’s performance on a quarterly basis and review each account’s portfolio and individual investments.
For investment management accounts, we require that each account be reviewed annually and most accounts are
reviewed quarterly. The nature and frequency of the reports to clients are determined primarily by the particular
needs of each client. Generally, we provide quarterly reports detailing the individual assets and performance of the
managed portfolio, unless the client requests information on a more frequent basis, to supplement the reports from
the custodian.
INSTITUTIONAL ACCOUNTS
For institutional clients, reviews are made by appropriate supervisory personnel. These individuals conduct client
portfolio reviews on a quarterly basis. Performance is measured and evaluated. Each client is expected to complete
an investment policy statement outlining the investment objectives, expectations, and guidelines. This investment
policy statement then serves as the benchmark, providing investment guidance to the client. Allocations are
reviewed against the investment policy statement to insure compliance within the framework of the client’s stated
objectives.
ACCOUNTS WITH OUTSIDE MANAGERS
When outside professional managers are used to managing all or a portion of an account, the following evaluation
process will be followed:
1. Measure rates of return for each fund net of investment manager fees and all fund expenses relative to a
peer group universe (benchmark) and other relevant market indices on a quarterly basis;
2. Determine progress towards achieving stated objectives in the investment policy statement—the primary
goal is to fulfill the values and goals as outlined;
3. Review fund characteristics including duration of manager with the fund, fund objective, style and
description of fund performance.
4. Provide comments and observations as it relates to funds investment objectives, style and performance.
Note deviations from stated policy, objectives and/or style. Note also any change in key personnel (fund
manager or research team);
Remove
Watch List);
‐
‐
5. Make recommendations for each fund (Hold
6. Recommend any new funds (if applicable) on a quarterly basis; and
7. Provide market and economic summary comments from the prior quarter and accompany it with as a
forecast for the coming period.
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ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
HUB Investment Partners receives client referrals from Charles Schwab & Co., Inc. (“Schwab”) through HUB
Investment Partners participation in Schwab Advisor Network® (“the Service”). The Service is designed to help
investors find an independent investment advisor. Schwab is a broker-dealer independent of and unaffiliated with
HUB Investment Partners. HUB Investment Partners pays Schwab fees to receive client referrals through the
Service (“Participation Fee”). HUB Investment Partners participation in the Service raises potential conflicts of
interest described below.
HUB Investment Partners pays Schwab a Participation Fee on all referred clients’ accounts that are maintained in
custody at Schwab and a separate one-time Transfer Fee on all accounts that are transferred to another custodian.
The Transfer Fee creates a conflict of interest that encourages HUB Investment Partners to recommend that client
accounts be held in custody at Schwab. The Participation Fee paid by HUB Investment Partners is a percentage of
the value of the assets in the client’s account. HUB Investment Partners pays Schwab the Participation Fee for so
long as the referred client’s account remains in custody at Schwab. The Participation Fee and any Transfer fee is
paid by HUB Investment Partners and not by the client. HUB Investment Partners has agreed not to charge clients
referred through the Service fees or costs greater than the fees or costs HUB Investment Partners charges clients
with similar portfolios who were not referred through the Service.
The Participation and Transfer Fees are based on assets in accounts of clients who were referred by Schwab and
those referred clients’ family members living in the same household. Thus, HUB Investment Partners has incentives
to recommend that client accounts and household members of clients referred through the Service maintain custody
of their accounts at Schwab.
HUB Investment Partners may pay referral fees to independent and/or affiliated promoter/solicitors for the referral
of clients to our firm in accordance with SEC regulations. Such referral fee represents a share of our investment
advisory fee charged to our clients. This arrangement will not result in higher costs to you. In this regard, we maintain
Promoter/Solicitors Agreements in compliance with SEC regulations. All clients referred by independent
promoter/solicitors to our firm will be given full written disclosure describing the terms and fee arrangements
between our firm and promoter/solicitor(s). In cases where state law requires licensure of promoter/solicitors, we
require that no solicitation fees are paid unless the promoter/solicitor is registered according to such state law
requirements. If we are paying solicitation fees to another registered investment adviser, the licensure of individuals
is the other firm’s responsibility. Similarly, HUB Investment Partners also may act as a referring agent to and receive
referral fees from independent registered investment advisers according to applicable state and federal law.
HUB Investment Partners also receives client referrals from certain of our affiliates, including employees of HUB
International Limited (“HUB”) through various divisions and Financial Coaches of RPW Solutions. In these
situations, we compensate the referring affiliate for the referral. Actual payment is dictated by the role of the referring
affiliate and internal organizational compensation policies and agreements. The compensation paid to Financial
Coaches of RPW Solutions for client referral to HIP is a percentage of the first year revenue earned on the referred
client assets. This presents a conflict of interest in that the Financial Coach is financially incentivized to refer the
client to HIP for investment advisory services based on the related compensation. The financial incentive
compensation paid to Financial Coaches does not increase the client fees. Similarly, we and/or our employees may
receive internal compensation for referring prospective or current clients to affiliated HUB businesses. In these
situations, referral compensation is paid by our affiliates out of their own assets and is not paid directly by the client.
Clients will not be charged additional fees beyond our fees for the services provided by our affiliates. The amount
of the referral credit could be calculated as a percent of the fees to be received in the referred client agreement over
a specified period after the referral or as a flat fee. Such compensation policies are structured to mitigate conflicts
of interest and to comply with applicable law, including regulations and guidance applicable to client portfolios
subject to ERISA and the applicable securities laws and regulations.
TCG Administrators currently provides direct or indirect compensation as a corporate partner and sponsor to various
associations for administrators, superintendents and various other state and local educational and governmental
organizations and associations. HUB Investment Partners may receive client referrals from these relationships.
From time to time, we may receive expense reimbursement for travel and/or marketing expenses from distributors
of investment and/or insurance products. Travel expense reimbursements are typically a result of attendance at
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due diligence and/or investment training events hosted by product sponsors. Marketing expense reimbursements
are typically the result of informal expense sharing arrangements in which product sponsors may underwrite costs
incurred for marketing such as advertising, publishing and seminar expenses. Although receipt of these travel and
marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor
reimbursements are typically made by those sponsors for whom sales have been made or it is anticipated sales will
be made.
Investment Advisor Representatives endeavor at all times to put the interest of our clients first as a part of their
fiduciary duty. However, you should be aware that the receipt of additional compensation through expense
reimbursements creates a conflict of interest that may impact the judgment of the IARs when making advisory
recommendations.
ITEM 15 – CUSTODY
INDIVIDUAL CLIENT MANAGED ACCOUNTS
HUB Investment Partners does not have, nor is it deemed to have, custody of the assets of individual clients under
the Custody Rule because we do not hold, directly or indirectly, a client’s funds or securities, nor do we have the
authority to obtain possession of them. Individual client accounts are maintained by unaffiliated qualified custodians
as defined under the Custody Rule. Clients will engage an independent broker-dealer/custodian to maintain their
account(s) and, as such, HIP will not have physical custody of Client assets, monies or securities. However, since
HIP may withdraw investment advisory fees directly from Clients’ accounts, as described in Item 5 - Fees and
Compensation, above, HIP is considered to have custody in a limited capacity. HIP is also deemed to have custody
of clients’ funds or securities when clients have standing written authorizations with their custodian to move money
from a client’s account to a third-party (“SLOA”) and under that SLOA authorize us to designate the amount or
timing of transfers to those specifically authorized account(s) with the custodian. The SEC has set forth a set of
standards intended to protect client assets in such situations, which we follow.
INSTITUTIONAL ACCOUNTS
As noted above for Individual Client Managed Accounts, for institutional Clients that we provide only investment
advisory services, we do not have, nor are we deemed to have, custody of a client’s assets under the Custody Rule
because we do not hold directly or indirectly, a client’s funds or securities, nor do we have the authority to obtain
possession of them. Such client funds or securities are maintained by unaffiliated qualified custodians as defined
under the Custody Rule.
For Clients that we act as the investment adviser and our affiliate, TCG Administrators, serves as the third party
administrator, we are deemed to have custody of such Clients’ funds and securities because TCG Administrators
have the ability to (a) deduct fees from these client accounts and/or (b) cause a qualified custodian holding client
assets to liquidate securities and distribute funds to a plan participant pursuant to a written request by such plan
participant (or the plan sponsor on behalf of such plan participant). TCG Administrators engage an independent
public accountant to conduct a Surprise Exam on an annual basis, which includes a review of the accounts at each
qualified custodian.
In situations in which TCG Administrators has custody or is deemed to have custody, TCG Administrators has
developed and implemented internal controls designed to protect our clients’ assets, including dual authorization
requirements for redemptions in and transfers from a client account.
ACCOUNT STATEMENTS
Clients will receive account statements from the appropriate qualified custodians. Clients should carefully review
those statements and clients are urged to compare the accounts statements received from the qualified custodians
with those they receive from us.
ITEM 16 – INVESTMENT DISCRETION
We usually receive discretionary authority from our clients at the outset of an advisory relationship to select the
identity and amount of securities to be bought or sold. Such discretion is to be exercised in a manner consistent
with the stated investment objectives for the particular client account.
When selecting securities and determining amounts to be invested in specific securities or sectors, we observe the
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investment policies, limitations, and restrictions of the clients for which the advice applies.
ITEM 17 – VOTING YOUR SECURITIES
As a matter of firm policy and practice, we do not vote proxies on behalf of advisory clients. Clients retain the
responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. We provide
advice to clients regarding the clients’ voting of proxies.
ITEM 18 – FINANCIAL INFORMATION
We do not require or solicit prepayment of more than $1,200 in advisory fees six months or more in advance. We
have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to our clients
and have not been the subject of a bankruptcy proceeding.