Overview
- Headquarters
- New Orleans, LA
- Average Client Assets
- $2.8 million
- SEC CRD Number
- 301715
Fee Structure
Primary Fee Schedule (HUBBELL STRICKLAND ADV 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $2,500,000 | 0.75% |
| $2,500,001 | and above | Negotiable |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | Negotiable | Negotiable |
| $10 million | Negotiable | Negotiable |
| $50 million | Negotiable | Negotiable |
| $100 million | Negotiable | Negotiable |
Clients
- HNW Share of Firm Assets
- 72.08%
- Total Client Accounts
- 1,236
- Discretionary Accounts
- 1,227
- Non-Discretionary Accounts
- 9
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients
Regulatory Filings
Primary Brochure: HUBBELL STRICKLAND ADV 2A (2026-03-19)
View Document Text
Disclosure Brochure
June 5, 2020
Item 1: Cover Page
Form ADV Part 2A Brochure
March 19, 2026
Hubbell Strickland Wealth Management, LLC
1100 Poydras Street, Suite 2010
New Orleans, LA 70163
(504) 832-3921
www.hubbellstrickland.com
info@hubbellstrickland.com
This brochure provides information about the qualifications and business practices of Hubbell Strickland
Wealth Management, LLC (hereinafter “HSWM" or the “Firm”). If you have any questions about the
contents of this brochure, please contact the Firm at this telephone number listed above. The information in
this brochure has not been approved or verified by the United States Securities and Exchange Commission
(SEC) or by any state securities authority. Additional information about the Firm is available on the SEC’s
website at www.adviserinfo.sec.gov. The Firm is a registered investment adviser. Registration does not
imply any level of skill or training.
Disclosure Brochure
Hubbell Strickland Wealth Management, LLC
Item 2. Material Changes
In this Item, HSWM is required to discuss any material changes that have been made to the brochure
since the last annual amendment.
In February of 2026, HSWM relocated its office from Suite 1150 to Suite 2010 within the same office
building located at 1100 Poydras Street, New Orleans, LA 70163. Please also refer to the items discussed
in Item 20 (Additional Information).
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Item 3. Table of Contents
Item 2. Material Changes ............................................................................................................................ 2
Item 3. Table of Contents ........................................................................................................................... 3
Item 4. Advisory Business .......................................................................................................................... 4
Item 5. Fees and Compensation ................................................................................................................... 6
Item 6. Performance-Based Fees and Side-by-Side Management ...................................................................... 9
Item 7. Types of Clients ............................................................................................................................. 9
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss .............................................................. 10
Item 9. Disciplinary Information ............................................................................................................... 12
Item 10. Other Financial Industry Activities and Affiliations .......................................................................... 12
Item 11. Code of Ethics ............................................................................................................................ 12
Item 12. Brokerage Practices ..................................................................................................................... 13
Item 13. Review of Accounts .................................................................................................................... 16
Item 14. Client Referrals and Other Compensation ....................................................................................... 17
Item 15. Custody ..................................................................................................................................... 17
Item 16. Investment Discretion .................................................................................................................. 18
Item 17. Voting Client Securities ............................................................................................................... 18
Item 18. Financial Information .................................................................................................................. 18
Item 19. Requirements for State-Registered Advisers ........................................................................................... 18
Item 20. Additional Information ................................................................................................................ 19
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Hubbell Strickland Wealth Management, LLC
Item 4. Advisory Business
HSWM offers a variety of advisory services, which include financial planning, consulting, and
investment management services. Prior to HSWM rendering any of the foregoing advisory services,
clients are required to enter into one or more written agreements with HSWM setting forth the relevant
terms and conditions of the advisory relationship (the “Advisory Agreement”).
HSWM has been operating as an investment advisory firm since May 2019 and is owned by Steven J.
Hubbell, Carson W. Strickland and Todd S. Hubbell through their respective limited liability holding
companies. As of 12/31/25, HSWM had $617,882,576 of assets under management, $573,671,736
of which was managed on a discretionary basis and $44,210,840 of which was managed on a non-
discretionary basis.
While this brochure generally describes the business of HSWM, certain sections also discuss the
activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other
persons occupying a similar status or performing similar functions), employees or any other person who
provides investment advice on HSWM’s behalf and is subject to the Firm’s supervision or control.
Financial Planning and Consulting Services
HSWM offers clients a broad range of financial planning and consulting services, which include any
or all of the following functions:
Business Planning
Retirement Planning
•
•
Cash Flow Forecasting
Risk Management
•
•
Trust and Estate Planning
Charitable Giving
•
•
Financial Reporting
Distribution Planning
•
•
Investment Consulting
Tax Planning
•
•
Insurance Planning
•
• Manager Due Diligence
While each of these services is available on a stand-alone basis, certain of them can also be rendered in
conjunction with investment portfolio management as part of a comprehensive wealth management
engagement (described in more detail below).
In performing these services, HSWM is not required to verify any information received from the client or
from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely
on such information. HSWM does recommend from time to time that clients engage the Firm for
additional related services, its Supervised Persons in their individual capacities as insurance agents or
4
representatives of a broker-dealer and/or other professionals
to
implement
registered
its
recommendations. Clients are advised that a conflict of interest exists if clients engage HSWM or its
affiliates to provide additional services for compensation. Clients retain absolute discretion over all
decisions regarding implementation and are under no obligation to act upon any of the recommendations
made by HSWM under a financial planning or consulting engagement. Clients are advised that it
remains their responsibility to promptly notify the Firm of any change in their financial situation or
investment objectives for the purpose of reviewing, evaluating or revising HSWM’s recommendations
and/or services.
Wealth Management Services
HSWM manages client investment portfolios on a discretionary or non-discretionary basis. In addition,
HSWM generally provides clients with wealth management services which include a broad range of
comprehensive financial planning and consulting services as well as discretionary and/or non-
discretionary management of investment portfolios.
HSWM primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”),
exchange-traded notes (“ETNs”), and individual debt and equity securities, options, alternative assets
and digital assets in accordance with their stated investment objectives.
Where appropriate, the Firm also provides advice about any type of legacy position or other investment
held in client portfolios. Clients can engage HSWM to manage and/or advise on certain investment
products that are not maintained at their primary custodian, such as variable life insurance and annuity
contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529
plans). In these situations, HSWM directs or recommends the allocation of client assets among the
various investment options available with the product. These assets are generally maintained at the
underwriting insurance company or the custodian designated by the product’s provider.
HSWM tailors its advisory services to meet the needs of its individual clients and seeks to ensure,
on a continuous basis, that client portfolios are managed in a manner consistent with those needs and
objectives. HSWM consults with clients on an initial and ongoing basis to assess their specific risk
tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their
portfolios. Clients are advised to promptly notify HSWM if there are changes in their financial situation
or if they wish to place any limitations on the management of their portfolios. Clients may impose
reasonable restrictions or mandates on the management of their accounts if HSWM determines, in its
sole discretion, the conditions would not materially impact the performance of a management strategy or
prove overly burdensome to the Firm’s management efforts.
For certain clients, HSWM allocates (and/or recommends that the client allocate) a portion of client’s
investment assets among unaffiliated independent investment managers (“Independent Manager(s)”) in
accordance with the client’s designated investment objective(s). The client may be required to enter into a
separate agreement with the Independent Manager(s), which will set forth the terms of the client’s
engagement with the Independent Manager(s). Clients are encouraged to review the separate account
manager’s Form ADV disclosure brochures for separate account manager fees, services offered and
conflicts prior to establishing an account with the separate account manager. Independent Manager(s)
will have day-to-day responsibility for the active discretionary management of the allocated assets. The
firm 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. The
factors the firm considers in recommending Independent Manager(s) include the client’s designated
investment objective(s), management style, performance, reputation, financial strength, reporting, pricing,
and research. The investment management fee charged by the Independent Manager(s) is separate from,
and in addition to, the firm’s advisory fee as set forth in Item 5.
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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). If HSWM recommends that a client roll over
their retirement plan assets into an account to be managed by the Firm, such a recommendation creates a
conflict of interest. HSWM will earn new (or increase its current) compensation as a result of the rollover.
No client is under any obligation to rollover retirement plan assets into an account managed by HSWM.
The Firm's Chief Compliance Officer, Carson Strickland, remains available to address any questions
that a client or prospective client may have regarding the potential for conflict of interest presented by
such rollover recommendation.
Retirement Plan Consulting Services
HSWM provides various consulting services to qualified employee benefit plans and their fiduciaries. This
suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing
their corporate retirement plans. Each engagement is individually negotiated and customized, and may
include any or all of the following services:
Plan Design and Strategy
Plan Review and Evaluation
•
•
•
Plan Fee and Cost Analysis
Plan Committee Consultation
Fiduciary and Compliance
Executive Planning & Benefits
•
•
•
•
Participant Education
Investment Selection
•
As disclosed in the Advisory Agreement, certain of the foregoing services are provided by HSWM as a
fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In
accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of
HSWM’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the
Firm reasonably expects under the engagement. This 408(b)(2) summary is prepared and provided to
clients by the plan's recordkeeper and/or third party administrator, subject to review by HSWM.
Item 5. Fees and Compensation
HSWM offers services on a fee basis, which may include fixed fees, as well as fees based upon assets
under management or advisement. Additionally, certain of the Firm’s Supervised Persons, in their
individual capacities, offer securities brokerage services and/or insurance products under a separate
commission-based arrangement.
Financial Planning and Consulting Fees
HSWM generally charges a fixed fee for providing financial planning and consulting services under a
stand-alone engagement. These fees are negotiable, but generally range from $1,000 to $25,000,
depending upon the scope and complexity of the services and the professional rendering the financial
planning and/or the consulting services. If the client engages the Firm for additional investment advisory
services, HSWM may offset all or a portion of its fees for those services based upon the amount paid for
the financial planning and/or consulting services.
The terms and conditions of the financial planning and/or consulting engagement are set forth in the
Advisory Agreement and HSWM generally requires one-half of the fee (estimated hourly or fixed)
payable upon execution of the Advisory Agreement. The outstanding balance is generally due upon
delivery of the financial plan or completion of the agreed upon services. The Firm does not,
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Hubbell Strickland Wealth Management, LLC
however, take receipt of $1,200 or more in prepaid fees in excess of six months in advance of services
rendered.
Wealth Management Fees
HSWM offers wealth management services for an annual fee based on the amount of assets under the
Firm’s management. This management fee generally varies depending upon the size and
composition of a client’s portfolio and the type of services rendered. The Firm's standard annual tiered
fee schedule is below:
Market Value of Portfolio
$0 to $1,000,000
$1,000,001 to $2,500,000
$2,500,001 and over
% of Assets
1.00%
0.75%
Negotiable
The annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets
being managed by HSWM on the last day of the previous billing period. Margin debit balances,
if applicable, do not reduce the billable value of the account. Depending on the nature of services
to be provided, the Firm may allow clients within the same household to aggregate account values
for the purpose of reaching fee breakpoints. If assets are deposited into or withdrawn from an
account after the inception of a billing period, the fee payable with respect to such assets is not adjusted to
reflect the interim change in portfolio value. For the initial period of an engagement, the fee is calculated
on a pro rata basis. In the event the advisory agreement is terminated, the fee for the final billing period
is prorated through the effective date of the termination and the outstanding or unearned portion of the
fee is refunded to the client, as appropriate.
Additionally, for asset management services the Firm provides with respect to certain client holdings
(e.g., held-away assets, accommodation accounts, alternative investments, etc.), HSWM may negotiate a
fee rate that differs from the range set forth above which depends on the responsibilities taken by the Firm
to manage or simply monitor the assets.
Retirement Plan Consulting Fees
HSWM may charge a fixed project-based fee to provide clients with retirement plan consulting services.
Each engagement is individually negotiated and tailored to accommodate the needs of the individual
plan sponsor, as memorialized in the Agreement. These fixed fees vary, based on the scope of the
services to be rendered, and may range up to $25,000. In those situations where HSWM has agreed to
manage a plan’s assets, the Firm may alternatively charge an annual asset-based fee between 0.15%
and 1.00%, depending upon the amount of assets to be managed. As noted above, HSWM
typically assesses advisory fees in advance on a quarterly basis. However, the annual asset based fee
for retirement plan advisory and consulting work may be charged in a different manner, i.e., in arrears,
and/or on a monthly as opposed to quarterly basis, depending on the retirement plan custodian selected.
Fee Discretion
HSWM may, in its sole discretion, negotiate to charge a lesser or greater fee based upon certain criteria,
such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to
be managed, related accounts, account composition, pre-existing/legacy client relationship, account
retention, level of complexity of services, and pro bono activities.
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Hubbell Strickland Wealth Management, LLC
Additional Fees and Expenses
In addition to the advisory fees paid to HSWM, clients may also incur certain charges imposed by other
third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions
(collectively “Financial Institutions”). These additional charges may include securities brokerage
commissions, transaction fees, custodial fees, margin costs, charges imposed directly by a mutual fund or
ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other
fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic
fund fees, and other fees and taxes on brokerage accounts and securities transactions. The Firm’s
brokerage practices are described at length in Item 12, below.
Direct Fee Debit
Clients generally provide HSWM with the authority to directly debit their accounts for payment of the
investment advisory fees. The Financial Institutions that act as the qualified custodian for client
accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send
statements to clients not less than quarterly detailing all account transactions, including any amounts paid
to HSWM.
Use of Margin
HSWM is authorized to use margin or other portfolio loans in the management of the client’s investment
portfolio. In such cases, the Firm's fees will be charged on the portfolio's marketable securities, and not
the account net of margin or other portfolio loans.
Account Additions and Withdrawals
Clients may make additions to and withdrawals from their account at any time, subject to HSWM’s
right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the
right to liquidate any transferred securities or declines to accept particular securities into a client’s
account. Clients may withdraw account assets on notice to HSWM, subject to the usual and customary
securities settlement procedures. However, the Firm generally designs its portfolios as long-term
investments and the withdrawal of assets may impair the achievement of a client’s investment objectives.
HSWM may consult with its clients about the options and implications of transferring securities. Clients
are advised that when transferred securities are liquidated, they may be subject to transaction fees,
short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges)
and/or tax ramifications.
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Hubbell Strickland Wealth Management, LLC
Commissions and Sales Charges for Recommendations of Securities
Clients can engage certain persons associated with HSWM (but not the Firm directly) to render securities
brokerage services under a separate commission-based arrangement. Clients are under no obligation to
engage such persons and may choose brokers or agents not affiliated with HSWM.
Under this arrangement, the Firm’s Supervised Persons, in their individual capacities as registered
representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”), provide securities brokerage
services and implement securities transactions under a separate commission-based arrangement.
Supervised Persons may be entitled to a portion of the brokerage commissions paid to PKS, as well as a
share of any ongoing distribution or service (trail) fees from the sale of mutual funds. HSWM may
also recommend no-load or load-waived funds, where no sales charges are assessed. Prior to effecting
any transactions, clients are required to enter into a separate account agreement with PKS.
A conflict of interest exists to the extent that HSWM recommends the purchase or sale of securities
where its Supervised Persons receive commissions or other additional compensation as a result of the
Firm’s recommendation. The Firm has procedures in place to ensure that any recommendations made by
such Supervised Persons are in the best interest of clients. For certain accounts covered by the Employee
Retirement Income Security Act of 1974 (“ERISA”) and such others that HSWM, in its sole discretion,
deems appropriate, HSWM may provide its investment advisory services on a fee-offset basis. In this
scenario, HSWM may offset its fees by an amount equal to the aggregate commissions and 12b-1 fees
earned by the Firm’s Supervised Persons in their individual capacities as registered representatives of
PKS.
Item 6. Performance-Based Fees and Side-by-Side Management
HSWM does not provide any services for a performance-based fee (i.e., a fee based on a share of capital
gains or capital appreciation of a client’s assets).
Item 7. Types of Clients
HSWM offers services to individuals, pension and profit sharing plans, trusts, estates, charitable
organizations, corporations and business entities.
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Hubbell Strickland Wealth Management, LLC
Minimum Account Requirements
HSWM does not impose a stated minimum fee or minimum portfolio value for starting and
maintaining an investment management relationship.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
HSWM primarily applies a fundamental approach to portfolio management. Fundamental analysis
concentrates on a company’s earnings, financial statements, and the quality of that company’s
management. These factors are then analyzed to determine the financial strength of a company. The
Firm’s investment philosophy is long-term in nature, based on research, principles and experience rather
than short-term trends. The Firm also focuses on asset allocation investment strategies to optimize the
risk and reward of a portfolio. An analysis of the returns, volatility and correlations of different asset
classes is conducted in order to create portfolios tailored to each client’s investment objectives,
investment time horizon, and risk tolerance. Investment research is performed through the use of
professional and public databases, paid subscriptions, financial publications and investment conferences.
Please note that a substantial risk in relying upon fundamental analysis is that, while the overall health
and position of a company may be good, evolving market conditions may negatively impact the security.
Investment Strategies
HSWM manages client assets on a discretionary or non-discretionary basis. The Firm primarily allocates
client assets among various mutual funds, exchange-traded funds (“ETFs”), exchange-traded notes
(“ETNs”), individual debt and equity securities, as well as alternative assets and digital assets, in
accordance with their stated investment objectives.
HSWM tailors its advisory services to the individual needs of clients. The Firm consults with clients
initially and on an ongoing basis to develop specific approaches to their investment needs. Investment
portfolios are constructed with the client’s objectives, risk tolerance and time horizon in mind. HSWM
strives to determine the appropriate level of investment risk in a client’s portfolio; however, investing
entrails the risk of loss, and clients should be prepared to bear such loss.
Cash Positions
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. All cash positions (money markets, etc.), including cash pending
investment or designated to be invested in the future, shall be included as part of assets under management
for purposes of calculating the advisory fee.
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Risk of Loss
Market Risks
Investing involves risk, including the potential loss of principal, and all investors should be guided
accordingly. The profitability of a significant portion of HSWM’s recommendations and/or investment
decisions may depend to a great extent upon correctly assessing the future course of price movements of
stocks, bonds and other asset classes. There can be no assurance that HSWM will be able to predict those
price movements accurately or capitalize on any such assumptions.
Mutual Funds, ETFs and ETNs
An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and
ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s
underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains,
as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities
for a profit that cannot be offset by a corresponding loss.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a
broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated
daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees,
redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day,
although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The
trading prices of a mutual fund’s shares may differ significantly from the NAV during periods of market
volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or
discount to actual NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary
market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at
least once daily for indexed based ETFs and potentially more frequently for actively managed ETFs.
However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata
NAV. There is also no guarantee that an active secondary market for such shares will develop or
continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually
20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular
ETF, a shareholder may have no way to dispose of such shares.
ETNs are an unsecured, unsubordinated debt instrument of the issuing financial institution and bear the
full credit risk of the issuer in addition to the risks of the underlying investments. Although ETNs are
designed to track the performance of an underlying group of investments, their performance may differ
significantly. Similar to ETFs, ETNs can be bought and sold throughout the day, and their price can
fluctuate throughout the day. ETNs may have a maturity date, subject to the instruction in the prospectus.
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Options
Options allow investors to buy or sell a security at a contracted “strike” price at or within a specific period
of time. Clients may pay or collect a premium for buying or selling an option. Investors transact in
options to either hedge (i.e., limit) losses in an attempt to reduce risk or to speculate on the performance
of the underlying securities. Options transactions contain a number of inherent risks, including the partial
or total loss of principal in the event that the value of the underlying security or index does not
increase/decrease to the level of the respective strike price. Holders of options contracts are also subject
to default by the option writer which may be unwilling or unable to perform its contractual obligations.
Item 9. Disciplinary Information
HSWM has not been involved in any legal or disciplinary events that are material to a client’s evaluation
of its advisory business or the integrity of its management.
Item 10. Other Financial Industry Activities and Affiliations
Registered Representatives of a Broker-Dealer
Certain of the Firm’s Supervised Persons are registered representatives of PKS and provide clients with
securities brokerage services under a separate commission-based arrangement. This arrangement is
described at length in Item 5.
Licensed Insurance Agents
One of the Firm’s Supervised Persons is a licensed insurance agent and can offer certain insurance
products on a fully disclosed commissionable basis. A conflict of interest exists to the extent that HSWM
recommends the purchase of insurance products where a Supervised Person is entitled to insurance
commissions or other additional compensation. The Firm has procedures in place whereby it seeks to
ensure that all recommendations are made in its clients’ best interest regardless of any such affiliations.
Item 11. Code of Ethics
HSWM has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”)
that sets forth the standards of conduct expected of its Supervised Persons. HSWM’s Code of Ethics
contains written policies reasonably designed to prevent certain unlawful practices such as the use of
material non-public information by the Firm or any of its Supervised Persons and the trading by the same
of securities ahead of clients in order to take advantage of pending orders.
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The Code of Ethics also requires certain of HSWM’s personnel to report their personal securities
holdings and transactions and obtain pre-approval of certain investments (e.g., initial public offerings,
limited offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities that it
also recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s
policies and procedures. This Code of Ethics has been established recognizing that some securities trade
in sufficiently broad markets to permit transactions by certain personnel to be completed without any
appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions
may be made to the policies stated below.
When the Firm is engaging in or considering a transaction in any security on behalf of a client, no
Supervised Person with access to this information may knowingly effect for themselves or for their
immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in
that security unless:
the transaction has been completed;
•
the transaction for the Supervised Person is completed as part of a batch trade with clients; or
•
a decision has been made not to engage in the transaction for the client.
•
These requirements are not applicable to: (i) direct obligations of the Government of the United States;
(ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper,
repurchase agreements and other high quality short-term debt instruments, including repurchase
agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit
investment trusts that are invested exclusively in one or more mutual funds.
Clients and prospective clients may contact HSWM to request a copy of its Code of Ethics.
Item 12. Brokerage Practices
Recommendation of Broker-Dealers for Client Transactions
HSWM generally recommends that clients utilize the custody, trading, brokerage and clearing services
of Fidelity Institutional Wealth Services (“Fidelity”) for investment management accounts.
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Factors which HSWM considers in recommending Fidelity or any other broker-dealer to clients include
their respective financial strength, reputation, execution, pricing, research and service. Fidelity enables the
Firm to obtain many mutual funds without transaction charges and other securities at nominal transaction
charges. The commissions and/or transaction fees charged by Fidelity may be higher or lower than those
charged by other Financial Institutions. The commissions paid by HSWM’s clients to Fidelity comply with
the Firm’s duty to obtain “best execution.” Clients may pay commissions that are higher than another
qualified Financial Institution might charge to effect the same transaction where HSWM determines that the
commissions are reasonable in relation to the value of the brokerage and research services received. In
seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction
represents the best qualitative execution, taking into consideration the full range of a Financial Institution’s
services, including among others, the value of research provided, execution capability, commission rates
and responsiveness. HSWM seeks competitive rates but may not necessarily obtain the lowest possible
commission rates for client transactions.
Consistent with obtaining best execution, brokerage transactions may be directed to certain broker-dealers
in return for investment research products and/or services which assist HSWM in its investment decision-
making process. Such research generally will be used to service all of the Firm’s clients, but brokerage
commissions paid by one client may be used to pay for research that is not used in managing that client’s
portfolio. The receipt of investment research products and/or services as well as the allocation of the
benefit of such investment research products and/or services poses a conflict of interest because HSWM
does not have to produce or pay for the products or services.
its policies and procedures
regarding
its
HSWM periodically and systematically reviews
recommendation of Financial Institutions in light of its duty to obtain best execution.
Software and Support Provided by Financial Institutions
HSWM receives, without cost from Fidelity, computer software and related systems support, which
allow HSWM to better monitor client accounts. HSWM receives the software and related support
without cost because the Firm renders investment management services to clients that maintain assets
at Fidelity. The software and support is not provided in connection with securities transactions of
clients (i.e., not “soft dollars”). The software and related systems support do benefit HSWM, but not its
clients directly. In fulfilling its duties to its clients, HSWM endeavors at all times to put the interests of
its clients first. Clients should be aware, however, that HSWM’s receipt of economic benefits from a
broker-dealer creates a conflict of interest since these benefits may influence the Firm’s choice of
broker-dealer over another that does not furnish similar software, systems support or services.
Specifically, HSWM receives the following benefits from Fidelity at no cost to HSWM:
• An online platform through which the Firm can monitor and review client accounts;
• Receipt of duplicate client confirmations and bundled duplicate statements;
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• Access to a trading desk that exclusively services its institutional traders;
• Access to block trading which provides the ability to aggregate securities transactions and then
allocate the appropriate shares to client accounts;
• Access to an electronic communication network for client order entry and account information;
• Practice management consulting; and
• Occasional business meals and entertainment.
The Firm also receives admission to educational and due diligence programs hosted by Fidelity at no cost
to HSWM. On occasion, the Firm receives admission to, and related travel and lodging costs for,
educational programs from other financial service companies, all at no cost to HSWM.
In addition, Fidelity provided financial assistance in connection with the formation of HSWM and its
registration as an investment adviser by covering certain costs incurred by the Firm related to entity
formation, branding, and portfolio accounting and reporting services. The receipt of these benefits
creates a conflict of interest to the extent that it causes the Firm to recommend Fidelity as opposed to
comparable custodial broker-dealers. The Firm addresses this conflict by fully disclosing it in this
brochure, evaluating Fidelity based on the value of its services as realized by the Firm's clients, and
periodically evaluating alternative custodial broker-dealers to recommend.
Brokerage for Client Referrals
HSWM does not consider, in selecting or recommending broker-dealers, whether the Firm receives
client referrals from the Financial Institutions or other third party.
Directed Brokerage
The client may direct HSWM in writing to use a particular Financial Institution to execute some or all
transactions for the client. In that case, the client will negotiate terms and arrangements for the account
with that Financial Institution and the Firm will not seek better execution services or prices from other
Financial Institutions or be able to “batch” client transactions for execution through other Financial
Institutions with orders for other accounts managed by HSWM (as described above). As a result, the
client may pay higher commissions or other transaction costs, greater spreads or may receive less
favorable net prices, on transactions for the account than would otherwise be the case. Subject to its duty
of best execution, HSWM may decline a client’s request to direct brokerage if, in the Firm’s sole
discretion, such directed brokerage arrangements would result in additional operational difficulties or
violate restrictions imposed by other broker-dealers (as further discussed below).
Commissions or Sales Charges for Recommendations of Securities
As discussed above, certain Supervised Persons in their respective individual capacities are registered
representatives of PKS. These Supervised Persons are subject to FINRA Rule 3040 which restricts
registered representatives from conducting securities transactions away from their broker-dealer unless
PKS provides written consent. Therefore, clients are advised that certain Supervised Persons are
restricted to conducting securities transactions through PKS if they have not secured written consent from
PKS to execute securities transactions though a different broker-dealer. Absent such written consent or
separation from PKS, these Supervised Persons are prohibited from executing securities transactions
through any broker-dealer other than PKS under its internal supervisory policies. The Firm is cognizant
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of its duty to obtain best execution and has implemented policies and procedures reasonably designed in
such pursuit.
Trade Aggregation
Transactions for each client generally will be effected independently, unless HSWM decides to
purchase or sell the same securities for several clients at approximately the same time. HSWM often
(but is not obligated to) does combine or “batch” such orders to obtain best execution, to negotiate
more favorable commission rates or to allocate equitably among the Firm’s clients differences in prices
and commissions or other transaction costs that might not have been obtained had such orders been
placed independently. Under this procedure, transactions will generally be averaged as to price and
allocated among HSWM’s clients pro rata to the purchase and sale orders placed for each client on any
given day. To the extent that the Firm determines to aggregate client orders for the purchase or sale of
securities, including securities in which HSWM’s Supervised Persons may invest, the Firm generally
does so in accordance with applicable rules promulgated under the Advisers Act and no-action
guidance provided by the staff of the U.S. Securities and Exchange Commission. HSWM does not
receive any additional compensation or remuneration as a result of the aggregation.
In the event that the Firm determines that a prorated allocation is not appropriate under the
particular circumstances, the allocation will be made based upon other relevant factors, which
include: (i) when only a small percentage of the order is executed, shares may be allocated to the
account with the smallest order or the smallest position or to an account that is out of line with
respect to security or sector weightings relative to other portfolios, with similar mandates; (ii)
allocations may be given to one account when one account has limitations in its investment guidelines
which prohibit it from purchasing other securities which are expected to produce similar investment
results and can be purchased by other accounts; (iii) if an account reaches an investment guideline
limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be
due to unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale
allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation
of a potential execution would result in a de minimis allocation in one or more accounts, the Firm
may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis
among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all
accounts, shares may be allocated to one or more accounts on a random basis.
Item 13. Review of Accounts
Account Reviews
HSWM monitors client portfolios on a continuous and ongoing basis, while regular account reviews are
typically conducted on at least an annual basis depending on the client's needs and preferences. Such
reviews are conducted by the Firm’s investment adviser representatives. All investment advisory clients
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are encouraged to discuss their needs, goals and objectives with HSWM and to keep the Firm informed of
any changes thereto.
Other factors that may trigger a review include, but are not limited to, material developments in market
conditions, material geopolitical events, and changes to a client's personal or financial situation.
The custodial broker-dealer for a client's account will send account statements and reports directly to
clients no less frequently than quarterly. Such statements and reports will be mailed to clients at their
address of record or delivered electronically, depending on the client's election.
Account Statements and Reports
Clients are provided with transaction confirmation notices and regular summary account statements
directly from the Financial Institutions where their assets are custodied. From time-to-time or as
otherwise requested, clients may also receive written or electronic reports from HSWM and/or an outside
service provider, which contain certain account and/or market-related information, such as an inventory
of account holdings or account performance. Clients should compare the account statements they receive
from their custodian with any documents or reports they receive from HSWM or an outside service
provider.
Item 14. Client Referrals and Other Compensation
Client Referrals
The Firm does not currently provide compensation to any third-party solicitors for client referrals. The
Firm does refer clients to professionals it knows who may be able to assist clients in matters
including, but not limited to, estate planning, tax preparation and legal services. These referrals are
provided as a courtesy to clients who are under no obligation to utilize the referred professionals. HSWM
has not entered into any referral arrangements with these providers but occasionally receives referrals
from these and other professionals. These referrals create a conflict of interest for the Firm in that it
financially benefits from referrals it receives from these professionals. The Firm mitigates this conflict
by selecting the professionals it refers based upon their competency and experience as opposed to any
referrals these professionals may provide to HSWM.
Item 15. Custody
The Advisory Agreement and/or the separate agreement with any Financial Institution generally
authorize HSWM to debit client accounts for payment of the Firm’s fees and to directly remit that those
funds to the Firm in accordance with applicable custody rules. The Financial Institutions that act as the
qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees,
have agreed to send statements to clients not less than quarterly detailing all account transactions,
including any amounts paid to HSWM.
In addition, as discussed in Item 13, HSWM may also send periodic supplemental reports to clients.
Clients should carefully review the statements sent directly by the Financial Institutions and compare
them to those received from HSWM.
For clients that do not have their fees deducted directly from their account(s) and have not provided
HSWM with any standing letters of authorization to distribute funds from their account(s), the Firm will
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not have custody of client funds or securities. For clients that have their fees deducted directly from their
account(s) or that have provided the Firm with discretion as to amount and timing of disbursements
pursuant to a standing letter of authorization to disburse funds from their account(s), the Firm will
typically be deemed to have limited custody over such clients' funds or securities pursuant to the SEC's
custody rule and subsequent guidance thereto. At no time will the Firm accept full custody of client funds
or securities in the capacity of a custodial broker-dealer, and at all times client accounts will be held by a
third-party qualified custodian as described in Item 12, above.
Item 16. Investment Discretion
HSWM may be given the authority to exercise discretion on behalf of clients. HSWM is considered to
exercise investment discretion over a client’s account if it can effect and/or direct transactions in client
accounts without first seeking their consent. HSWM is given this authority through a power-of-attorney
included in the agreement between HSWM and the client. Clients may request a limitation on this
authority (such as certain securities not to be bought or sold). HSWM takes discretion over the following
activities: the securities to be purchased or sold; the amount of securities to be purchased or sold; and
when transactions are made.
Item 17. Voting Client Securities
Declination of Proxy Voting Authority
HSWM generally does not accept the authority to vote a client’s securities (i.e., proxies) on their behalf.
Clients receive proxies directly from the Financial Institutions where their assets are custodied and may
contact the Firm at the contact information on the cover of this brochure with questions about any such
issuer solicitations.
Item 18. Financial Information
• The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or
more in advance of services rendered;
• The Firm does not have a financial condition that is reasonably likely to impair its ability to meet
contractual commitments to clients; and
• The Firm has not been the subject of a bankruptcy petition at any time during the past ten years.
Item 19. Requirements for State-Registered Advisers
HSWM is a federally registered investment adviser; therefore, HSWM is not required to respond to
this item.
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Item 20. Additional Information
Trade Errors
In the event a trading error occurs in a client’s account, the Firm’s policy is to restore the account to the position it
should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may
include canceling the trade, adjusting an allocation, and/or reimbursing the account.
Class Action Lawsuits
HSWM does not determine if securities held by clients are the subject of a class action lawsuit or whether clients
are eligible to participate in class action settlements or litigation, nor does the Firm initiate or participate in
litigation to recover damages on a client’s behalf for injuries as a result of actions, misconduct, or negligence by
issuers of securities held by that client.
IRA Rollover Considerations and Recommendations
For purposes of complying with the Department of Labor’s Prohibited Transaction Exemption 2020-02 ("PTE
2020-02"), HSWM is providing the following information to you as a client or prospective client. When the Firm
provides investment advice to you regarding your retirement plan account or individual retirement account, the
Firm is a fiduciary 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. The way the Firm makes
money creates conflicts with your interests, so we operate under a special rule that requires us to act in your best
interest and not put our interest ahead of yours. Under this special rule's provisions, the Firm must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than reasonable compensation for our services; and
• Give you basic information about conflicts of interest.
The Firm may recommend that you withdraw assets from your employer's retirement plan and roll the assets over to
an individual retirement account ("IRA"). In most cases, the Firm benefits financially from the rollover of assets
from a retirement account to an account that it manages, as those assets increase the Firm’s assets under
management and, in turn, may increase the Firm’s advisory fees.
As a fiduciary, the Firm only recommends a rollover when it believes the rollover is in your best interest. Clients
and prospective clients are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if a
rollover is completed, there is no obligation to have the assets in an IRA managed by the Firm. Clients and
prospective clients should consider the costs and benefits of:
1. Leaving the funds in your employer's (former employer's) plan.
2. Moving the funds to a new employer's retirement plan.
3. Cashing out and taking a taxable distribution from the plan.
4. Rolling the funds into an IRA rollover account.
Each of these options has advantages and disadvantages. It is important that you understand the differences
between these types of accounts and decide whether a rollover is best for you. Prior to proceeding, if you have
questions, contact your investment adviser representative, or call our main number as listed on the cover page of
this brochure.
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