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Item 1
Cover Page
HWA Financial Group
Brochure
Dated: March 20, 2026
Contact: Philip Huber, Jr., Chief Compliance Officer
3448 Ellicott Center Drive, Suite 101
Ellicott City, Maryland 21043
This brochure provides information about the qualifications and business practices of HWA
Financial Group. If you have any questions about the contents of this brochure, please contact us at
(410) 696-4025 or phuber@hwafinancialgroup.com. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission or by any state
securities authority.
Additional information about HWA Financial Group also is available on the SEC’s website at
www.adviserinfo.sec.gov.
References herein to HWA Financial Group as a “registered investment adviser” or any reference to
being “registered” does not imply a certain level of skill or training.
Item 2
Material Changes
The firm does not have any material changes to report since its last annual amendment update which was
filed on March 28, 2025.
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
Fees and Compensation ................................................................................................................ 7
Item 5
Performance-Based Fees and Side-by-Side Management .......................................................... 10
Item 6
Item 7
Types of Clients .......................................................................................................................... 10
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................... 10
Item 9 Disciplinary Information ............................................................................................................ 13
Item 10 Other Financial Industry Activities and Affiliations .................................................................. 13
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.............. 14
Item 12 Brokerage Practices .................................................................................................................... 15
Item 13 Review of Accounts .................................................................................................................... 16
Item 14 Client Referrals and Other Compensation .................................................................................. 17
Item 15 Custody ....................................................................................................................................... 17
Item 16
Investment Discretion ................................................................................................................. 17
Item 17 Voting Client Securities .............................................................................................................. 18
Item 18 Financial Information ................................................................................................................. 18
Information Required by Part 2B of Form ADV: Brochure Supplement
Philip E. Huber, Jr., President…………………………………………………………………….19
Joseph R. Geld, Investment Advisor Representative……………………………………………..23
Daniel S. Pereira, Investment Advisor Representative…………………………………………...27
Privacy Policy…………………………………………………………………………………………......30
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Item 4
Advisory Business
A. Huber, Weakland & Associates, Inc., doing business as “HWA Financial Group” (the
“Registrant”), is a corporation formed in the State of Maryland. The Registrant became
registered as an Investment Adviser Firm in September 1999 and Philip Huber, Jr. is the
firm’s principal owner.
B.
HWA WEALTH INVESTMENT ADVISORY SERVICES
The Registrant provides discretionary investment advisory services on a fee basis. The
Registrant’s annual investment advisory fee is based upon a percentage (%) of the market
value of the assets placed under the Registrant’s management, generally between
negotiable and 1.00%.
Registrant's annual investment advisory fee shall include investment advisory services,
and, to the extent specifically requested by the client, financial planning and consulting
services. In the event that the client requires extraordinary planning and/or consultation
services (to be determined in the sole discretion of the Registrant), the Registrant may
determine to charge for such additional services, the dollar amount of which shall be set
forth in a separate written notice to the client.
FINANCIAL PLANNING SERVICES (STAND-ALONE)
The Registrant may be engaged to provide financial planning services (including
investment and non-investment related matters, including estate planning, insurance
planning, etc.) on a stand-alone separate fee basis. Registrant’s planning fees are
negotiable, but generally range from $150 to $250 on an hourly rate basis, depending upon
the level and scope of the service(s) required and the professional(s) rendering the
service(s). Prior to engaging the Registrant to provide planning services, clients are
generally required to enter into a Financial Planning Agreement with Registrant setting
forth the terms and conditions of the engagement (including termination), describing the
scope of the services to be provided, and the portion of the fee that is due from the client
prior to Registrant commencing services. If requested by the client, Registrant may
recommend the services of other professionals for implementation purposes. The client is
under no obligation to engage the services of any such recommended professional. The
client retains absolute discretion over all such implementation decisions and is free to
accept or reject any recommendation from the Registrant. If the client engages any such
recommended professional, and a dispute arises thereafter relative to such engagement, the
client agrees to seek recourse exclusively from and against the engaged professional.
It shall remain the client’s responsibility to promptly notify the Registrant if there is ever
any change in their financial situation or investment objectives for the purpose of
reviewing, evaluating or revising Registrant’s previous recommendations and/or services.
INVESTMENT CONSULTING SERVICES
Registrant provides investment consulting services on assets which fall outside the
definition of “regulatory assets under management” (AUM). Through this service the
Registrant may provide investment recommendations to the client. However, the client
shall make the ultimate portfolio decisions.
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Each investment consulting engagement is unique. Prior to engaging the Registrant to
provide consulting services, clients are generally required to enter into a Investment
Consulting Agreement with Registrant setting forth the terms, conditions, and services of
the engagement.
RETIREMENT PLAN SERVICES
The Registrant also provides retirement plan services to sponsors of self-directed
retirement plans and defined benefit plans organized under the Employee Retirement
Security Act of 1974 (“ERISA”). The Registrant performs these services in an ERISA
Section 3(21) capacity, by assisting with the development of investment policy
statements, and then the selection and monitoring of investment alternatives from which
plan participants may choose in self-directing the investments for their individual plan
retirement accounts. Upon request by the plan sponsor, Registrant may also provide
participant education designed to assist participants in identifying the appropriate
investment strategy for their retirement plan accounts. The terms and conditions of the
engagement between the Registrant and the plan sponsor will be set forth in a Retirement
Plan Services Agreement.
MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. As indicated above, to the extent requested by a client, we may provide financial
planning and related consulting services regarding non-investment related matters, such as
estate planning, tax planning, insurance, etc. The Registrant does not serve as an attorney,
accountant and no portion of our services should be construed as legal or accounting
services. Accordingly, we do not prepare estate planning documents or tax returns. To the
extent requested by a client, we may recommend the services of other professionals for
certain non-investment implementation purpose (i.e. attorneys, accountants, insurance,
etc.). Clients are reminded that they are under no obligation to engage the services of any
such recommended professional. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation made by
Registrant or its representatives. Please Note: If the client engages any unaffiliated
recommended professional, and a dispute arises thereafter relative to such engagement, the
client agrees to seek recourse exclusively from and against the engaged professional.
Retirement Plan Rollovers – No Obligation / 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 the Registrant recommends
that a client roll over their retirement plan assets into an account to be managed by the
Registrant, such a recommendation creates a conflict of interest if the Registrant will earn
an advisory fee on the rolled over assets. No client is under any obligation to roll over
retirement plan assets to an account managed by Registrant.
Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded
funds are available directly to the public. Thus, a prospective client can obtain many of the
funds that may be utilized by Registrant independent of engaging Registrant as an
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investment advisor. However, if a prospective client determines to do so, he/she will not
receive the Registrant’s initial and ongoing investment advisory services.
In addition to Registrant’s investment advisory fee described below, and transaction and/or
custodial fees discussed below, clients will also incur, relative to all mutual fund and
exchange traded fund purchases, charges imposed at the fund level (e.g. management fees
and other fund expenses).
investment objectives. Factors considered
Independent Managers. Registrant may allocate (and/or recommend that the client
allocate) a portion of a client’s investment assets among unaffiliated independent
investment managers (“Independent Manager(s)”) in accordance with the client’s
designated investment objective(s). In such situations, the Independent Manager(s) shall
have day-to-day responsibility for the active discretionary management of the allocated
assets. Registrant shall continue to render investment supervisory services to the client
relative to the ongoing monitoring and review of account performance, asset allocation and
client
in recommending Independent
Manager(s) include the client’s designated investment objective(s), management style,
performance, reputation, financial strength, reporting, pricing, and research. Please Note:
The investment management fee charged by the Independent Manager(s) is separate from,
and in addition to, Registrant’s advisory fee as set forth in the fee schedule at Item 5 below
and which will be disclosed to the client before entering into the Independent Manager
engagement and/or subject to the terms and conditions of a separate agreement between
the client and the Independent Manager(s). Please Also Note: If an Independent Manager
is selected, Registrant and client will work together to determine if asset-based pricing or
transactional pricing is most appropriate.
Recommendation of Unaffiliated Sub-Managers. The Registrant may recommend the
use of a broker/dealer Sub-Manager relationship. The broker/dealer Sub-Managers are
dually registered as both a broker/dealers and investment advisors. To the extent engaged,
broker/dealer Sub-Managers manage client assets on a commission basis. Through such an
arrangement, the client will open a commission-only account where the broker/dealer Sub-
Manager manages a pre-determined portion of the client’s assets on a discretionary basis
using investment strategies and methods of the broker/dealer Sub-Manager. The Registrant
does not receive any portion of the commissions and trading expenses charged by the
broker/dealer Sub-Manager. All commissions and other charges are retained entirely by
the broker/dealer Sub-Manager.
Please Note: The fees charged by the broker/dealer Sub-Manager are separate from, and
in addition to, Registrant’s advisory fee as set forth in the fee schedule at Item 5 below and
which will be disclosed to the client before entering into the engagement with the
broker/dealer Sub-Manager and/or subject to the terms and conditions of a separate
agreement between the client and the broker/dealer Sub-Manager.
Please Note: Clients that choose to engage a broker/dealer Sub-Manager must understand
that the arrangement is different from a third-party investment manager acting as an
independent manager and/or sub-advisor. Broker/dealers are not held to the same fiduciary
standard as an investment advisor. Therefore, a broker/dealer does not have a fiduciary
duty to always act in the best interests of its clients. Broker/dealers are held to a
“suitability” standard which requires them to recommend investments suitable to the client.
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As the broker/dealer Sub-Manager relationship typically recommended by the Registrant
will provide the broker/dealer Sub-Manager with discretionary authority over client’s
assets the broker/dealer Sub-Manager has a conflict of interest because the broker/dealer
receives a commission for every transaction in the account. Therefore, the broker/dealer
could implement trades based on economic interests and not the investment interests of the
client.
Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the
client’s best interest. As part of its investment advisory services, Registrant will review
client portfolios on an ongoing basis to determine if any changes are necessary based upon
various factors, including, but not limited to, investment performance, fund manager
tenure, style drift, account additions/withdrawals, and/or a change in the client’s
investment objective. Based upon these factors, there may be extended periods of time
when Registrant determines that changes to a client’s portfolio are neither necessary nor
prudent. Of course, as indicated below, there can be no assurance that investment decisions
made by Registrant will be profitable or equal any specific performance level(s).
Client Obligations. In performing its services, Registrant shall not be required to verify
any information received from the client or from the client’s other professionals, and is
expressly authorized to rely thereon. Moreover, each client is advised that it remains their
responsibility to promptly notify the Registrant if there is ever any change in their financial
situation or investment objectives for the purpose of reviewing, evaluating or revising
Registrant’s previous recommendations and/or services.
Disclosure Statement. A copy of the Registrant’s written Brochure as set forth on Part 2A
of Form ADV shall be provided to each client prior to, or contemporaneously with, the
execution of the Investment Advisory Agreement, Financial Planning Agreement,
Investment Consulting Agreement, or the Retirement Plan Services Agreement.
to providing
investment advisory services, an
C. The Registrant shall provide investment advisory services specific to the needs of each
client. Prior
investment adviser
representative will ascertain each client’s investment objective(s). Thereafter, the
Registrant shall allocate and/or recommend that the client allocate investment assets
consistent with the designated investment objective(s). The client may, at any time, impose
reasonable restrictions, in writing, on the Registrant’s services.
D. The Registrant does not participate in a wrap fee program.
E. As of December 31, 2025, the Registrant manages $267,113,334 of assets on a
discretionary basis and $28,200,400 on a non-discretionary basis.
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Item 5
Fees and Compensation
A.
HWA WEALTH INVESTMENT ADVISORY SERVICES
If a client determines to engage the Registrant to provide discretionary investment advisory
services on a fee basis, the Registrant’s annual investment advisory fee shall be based upon
a percentage (%) of the market value and type of assets placed under the Registrant’s
management (between negotiable and 1.00%) as follows:
Client Assets
First $1,000,000
Next $2,000,000
Next $2,000,000
Amounts over $5,000,001
Annual Fee
1.00%
0.70%
0.50%
0.30%
Valuation
For purposes of determining value, securities and other instruments traded on a market for
which actual transaction prices are publicly reported are valued at the last reported sale
price on the principal market in which they are traded.
The value for all private investment funds will reflect the most recent valuation provided
by the fund sponsor. However, if subsequent to purchase, the fund has not provided an
updated valuation, the valuation shall reflect the initial purchase price. If subsequent to
purchase, the fund provides an updated valuation, then the valuation will reflect that
updated value. The updated value will continue to be reflected on this report until the fund
provides a further updated value. Please Also Note: As result of the valuation process, if
the valuation reflects initial purchase price or an updated value subsequent to purchase
price, the current value could be significantly more or less than the value reflected on report
or invoice.
Fees are Negotiable
The Registrant’s investment advisory fee is negotiable at Registrant’s discretion,
depending upon objective and subjective factors including but not limited to: the amount
of assets to be managed; portfolio composition; the scope and complexity of the
engagement; the anticipated number of meetings and servicing needs; related accounts;
future earning capacity; anticipated future additional assets; the professional(s) rendering
the service(s); prior relationships with the Registrant and/or its representatives, and
negotiations with the client. As a result of these factors, similarly situated clients could pay
different fees, the services to be provided by the Registrant to any particular client could
be available from other advisers at lower fees, and certain clients may have fees different
than those specifically set forth above.
Use of Margin and Pledged Asset Line from Account Custodian
Registrant does not recommend using margin to implement its discretionary investment
strategies. However, from time to time, clients may determine to accept pledge asset loans
or use margin from their account’s custodian. In addition, Registrant may recommend the
use of a broker/dealer Sub-Manager that does use margin. In either scenario, the client will
generally be required to post collateral to secure the pledge asset loan or the use of margin
and will pay interest on borrowed money. The account managed by Registrant or
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broker/dealer Sub-Manager will typically be used as that collateral. If the securities in the
client’s account decline in value, so does the value of the collateral supporting the margin
loan or pledge asset loan, and as a result, the client’s custodian may take action, such as
issue a margin call and/or sell securities in the account, in order to maintain the required
equity.
In calculating the advisory fee when the account includes a pledged asset loan, the total
absolute value of the securities in the client’s account, long or short, plus all credit balance,
with no offset for any pledged asset loan, unless it agrees to other arrangements with a
client.
In calculating the advisory fee when the account includes a margin loan, the total absolute
value of the securities in the client’s account, long or short, plus all credit balance, less any
margin balance.
Registrant therefore is conflicted when it (i) recommends that clients take loans from their
account custodian, (ii) recommends that client use and continue using loans, and (iii) when
recommending an account custodian as a lender to clients, because in each instance,
Registrant could otherwise suggest that the client sell securities in their account. Clients
remain solely responsible for determining, whether to use or continue using margin or
taking loans from their account custodian. Registrant’s Chief Compliance Officer remains
available to address any questions that client or prospective client may have regarding the
above conflict of interest.
FINANCIAL PLANNING SERVICES (STAND-ALONE)
The Registrant may be engaged to provide financial planning services (including
investment and non-investment related matters, including estate planning, insurance
planning, etc.) on a stand-alone fee basis. Registrant’s planning fees are negotiable, but
generally range from $150 to $250 on an hourly rate basis, depending upon the level and
scope of the service(s) required and the professional(s) rendering the service(s). Lower fees
for comparable financial planning services may be available from other sources.
INVESTMENT CONSULTING
This service is typically provided either quarterly, semi-annually or annually for an agreed
upon fee. The actual fee charged to a client can vary greatly and is determined by the
Registrant based on factors such as, but not limited to, the number of accounts being
reviewed, the total amount of assets being reviewed, the number of investment managers
used by the client, the type of investments, frequency of reports and meetings, and the
overall nature and scope of the project. A typical fee for investment consulting services
can range from $10,000 to $70,000; however, the actual fee charged to each client may be
higher or lower. After the report has been presented, the Registrant will issue an invoice
and the fee is due upon receipt. Lower fees for comparable investment consulting services
may be available from other sources.
RETIREMENT PLAN SERVICES
The terms and conditions of the Registrant’s retirement plan services shall generally be set
forth in a Retirement Plan Agreement between the Registrant and the plan sponsor.
Registrant’s negotiable retirement plan fees generally range between 0.20% and 0.75% of
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the value of plan assets under advisement, depending upon the level and scope of the
service(s) required and the professional(s) rendering the service(s).
B. Clients may elect to have the Registrant’s advisory fees deducted from their custodial
account. Both Registrant's Investment Advisory Agreement and the custodial/clearing
agreement may authorize the custodian to debit the account for the amount of the
Registrant's investment advisory fee and to directly remit that management fee to the
Registrant in compliance with regulatory procedures. In the limited event that the
Registrant bills the client directly, payment is due upon receipt of the Registrant’s invoice.
The Registrant shall deduct fees and/or bill clients quarterly in advance, based upon the
market value of the assets on the last business day of the previous quarter.
C. As discussed below, unless the client directs otherwise or an individual client’s
circumstances require, the Registrant shall generally recommend that Charles Schwab and
Co., Inc. (“Schwab”) serve as the broker-dealer/custodian for client investment
management assets. Broker-dealers such as Schwab charge brokerage commissions and/or
transaction fees for effecting certain securities transactions (i.e. transaction fees are charged
for certain no-load mutual funds, commissions are charged for individual equity and fixed
income securities transactions). In addition to Registrant’s investment management fee,
brokerage commissions and/or transaction fees, clients will also incur, relative to all mutual
fund and exchange traded fund purchases, charges imposed at the fund level (e.g.
management fees and other fund expenses).
Tradeaway/Prime Broker Fees. If, in the reasonable determination of Registrant that it
would be beneficial for the client, individual equity and/or fixed income transactions may
be effected through broker-dealers other than the account custodian, in which event, the
client generally will incur both the fee (commission, mark-up/mark-down) charged by the
executing broker-dealer and a separate “tradeaway” and/or prime broker fee charged by
the account custodian (i.e., Schwab).
D. Registrant's annual investment advisory fee shall be prorated (with the exception of the
Aspire Program, which are not prorated) and paid quarterly, in advance, based upon the
market value of the assets on the last business day of the previous quarter.
The Registrant, in its sole discretion, may reduce its investment management fee and/or
reduce or waive its first-year fee requirement based upon certain criteria (i.e. anticipated
future earning capacity, anticipated future additional assets, dollar amount of assets to be
managed, related accounts, account composition, negotiations with client, etc.).
The Investment Advisory Agreement between the Registrant and the client will continue in
effect until terminated by either party by written notice in accordance with the terms of the
Investment Advisory Agreement. Upon termination, the Registrant shall refund the pro-
rated portion of the advanced advisory fee paid based upon the number of days remaining
in the billing quarter.
E. Neither the Registrant, nor its representatives accept compensation from the sale of
securities or other investment products.
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Item 6
Performance-Based Fees and Side-by-Side Management
Neither the Registrant nor any supervised person of the Registrant accepts performance-
based fees.
Item 7
Types of Clients
The Registrant’s clients shall generally include individuals, business entities, trusts, and
charitable organizations.
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
A. The Registrant may utilize the following methods of security analysis:
• Charting - (analysis performed using patterns to identify current trends and trend
reversals to forecast the direction of prices)
• Fundamental - (analysis performed on historical and present data, with the goal of
making financial forecasts)
• Technical – (analysis performed on historical and present data, focusing on price
and trade volume, to forecast the direction of prices)
The Registrant may utilize the following investment strategies when implementing
investment advice given to clients:
• Long Term Purchases (securities held at least a year)
• Short Term Purchases (securities sold within a year)
• Trading (securities sold within thirty (30) days)
Please Note: Investment Risk. Different types of investments involve varying degrees of
risk, and it should not be assumed that future performance of any specific investment or
investment strategy (including the investments and/or investment strategies recommended
or undertaken by the Registrant) will be profitable or equal any specific performance
level(s).
B. The Registrant’s methods of analysis and investment strategies do not present any
significant or unusual risks. However, every method of analysis has its own inherent risks.
To perform an accurate market analysis, the Registrant must have access to current/new
market information. The Registrant has no control over the dissemination rate of market
information; therefore, unbeknownst to the Registrant, certain analyses may be compiled
with outdated market information, severely limiting the value of the Registrant’s analysis.
Furthermore, an accurate market analysis can only produce a forecast of the direction of
market values. There can be no assurances that a forecasted change in market value will
materialize into actionable and/or profitable investment opportunities.
The Registrant’s primary investment strategies (Long Term Purchases, Short Term
Purchases, and Trading) are fundamental investment strategies. However, every
investment strategy has its own inherent risks and limitations. For example, longer term
investment strategies require a longer investment time period to allow for the strategy to
potentially develop. Shorter-term investment strategies require a shorter investment time
period to potentially develop but, as a result of more frequent trading, may incur higher
10
transactional costs when compared to a longer-term investment strategy. Trading, an
investment strategy that requires the purchase and sale of securities within a thirty (30) day
investment time period, involves a very short investment time period but will incur higher
transaction costs when compared to a short-term investment strategy and substantially
higher transaction costs than a longer-term investment strategy.
C. Currently, Registrant primarily allocates investment management assets of its client
accounts among individual debt and equity securities, various mutual fund classes, and
exchange traded funds (ETFs) on a discretionary basis, in accordance with the client’s
designated investment objective(s). On occasion, private investments are used to
implement client objectives.
Registrant’s asset allocation strategies have been designed to comply with the requirements
of Rule 3a-4 of the Investment Company Act of 1940. Rule 3a-4 provides similarly
managed investment programs, such as Registrant’s asset allocation programs, with a non-
exclusive safe harbor from the definition of an investment company. In accordance with
Rule 3a-4, the following disclosure is applicable to Registrant’s management of client
assets:
1. Initial Interview – at the opening of the account, the Registrant, through its designated
representatives, shall obtain from the client information sufficient to determine the client’s
financial situation and investment objectives;
2. Individual Treatment - the account is managed on the basis of the client’s financial
situation and investment objectives;
3. Quarterly Notice – at least quarterly the Registrant shall notify the client to advise the
Registrant whether the client’s financial situation or investment objectives have changed,
or if the client wants to impose and/or modify any reasonable restrictions on the
management of the account;
4. Annual Contact – at least annually, the Registrant shall contact the client to determine
whether the client’s financial situation or investment objectives have changed, or if the
client wants to impose and/or modify any reasonable restrictions on the management of the
account;
5. Consultation Available – the Registrant shall be reasonably available to consult with
the client relative to the status of the account;
6. Quarterly Report – the client shall be provided with a quarterly report for the account
for the preceding period;
7. Ability to Impose Restrictions – the client shall have the ability to impose reasonable
restrictions on the management of the account, including the ability to instruct the
Registrant not to purchase certain securities;
8. No Pooling – the client’s beneficial interest in a security does not represent an undivided
interest in all the securities held by the custodian, but rather represents a direct and
beneficial interest in the securities which comprise the account;
9. Separate Account - a separate account is maintained for the client with the Custodian;
10. Ownership – each client retains indicia of ownership of the account (e.g. right to
withdraw securities or cash, exercise or delegate proxy voting, and receive transaction
confirmations).
The Registrant believes that its annual investment management fee is reasonable in relation
to: (1) the advisory services provided under the Investment Advisory Agreement; and (2)
the fees charged by other investment advisers offering similar services/programs.
However, Registrant’s annual investment advisory fee may be higher than that charged by
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other investment advisers offering similar services/programs. In addition to Registrant’s
annual investment management fee, the client will also incur charges imposed directly at
the mutual fund, exchange traded fund, independent manager, and unaffiliated sub-manger
level (e.g., management fees and other fund expenses). Please Note: Upon reviewing
client portfolios, the Registrant may determine no changes are necessary. As a result, some
clients may experience little to no turnover. Please Also Note: Registrant’s investment
programs may involve above-average portfolio turnover which could negatively impact
upon the net after-tax gain experienced by an individual client in a taxable account.
ETFs. ETFs in which the strategy may invest involve certain inherent risks generally
associated with investments in a portfolio of securities, including the risk that the general
level of security prices may decline, thereby adversely affecting the value of each unit of
the ETF. Moreover, an ETF may not fully replicate the performance of its benchmark index
because of the temporary unavailability of certain index securities in the secondary market
or discrepancies between the ETF and the index with respect to the weighting of securities
or the number of securities held. ETFs in which the strategies invest have their own fees
and expenses as set forth in the ETF prospectuses. ETFs may have exposure to derivative
instruments, such as futures contracts, forward contracts, options, and swaps. There is a
risk that a derivative may not perform as expected. The main risk with derivatives is that
some types can amplify a gain or loss, potentially earning or losing substantially more
money than the actual cost of the derivative, or that the counterparty may fail to honor its
contract terms, causing a loss for the ETF. Use of these instruments may also involve
certain costs and risks such as liquidity risk, interest rate risk, market risk, credit risk,
management risk, and the risk that an ETF could not close out a position when it would be
most advantageous to do so. Some ETFs available, including Schwab ETFs™, are less than
10 years old. Accordingly, there is limited data available to use when assessing the
investment risk of some of these ETFs. As a result, one or more of the following may occur:
(i) poor liquidity in or limited availability of the ETFs, or (ii) lack of market depth causing
the ETFs to trade at excessive premiums or discounts.
Cryptocurrency ETF Risks: Cryptocurrency related ETFs are currently considered to be
a speculative investment. Cryptocurrency’s value is completely derived by market forces of
supply and demand, and they are more volatile than traditional currencies. The value of
cryptocurrency may be derived from the continued willingness of market participants to
exchange fiat currency for cryptocurrency, which may result in the potential for a permanent
and total loss of value of a particular cryptocurrency should the market for that
cryptocurrency disappear. Cryptocurrencies are not covered by either FDIC or SIPC
insurance. Legislative and regulatory changes or actions at the state, federal, or international
level may adversely affect the use, transfer, exchange, and value of cryptocurrency.
Additionally, purchasing cryptocurrencies or cryptocurrency funds comes with several other
risks, including volatile market price swings or flash crashes, fraud, market manipulation,
and cybersecurity risks. In addition, cryptocurrency markets and exchanges are not
regulated with the same controls or customer protections available in equity, option, futures,
or foreign exchange investing. There is no assurance that a person who accepts a
cryptocurrency as payment today will continue to do so in the future.
Investment Strategy Risks. There are risks associated with the long-term core strategic
holdings for each of the investment strategies. The more aggressive the investment strategy
selected, the more likely the portfolio will contain larger weights in riskier asset classes,
such as equities.
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Item 9
Disciplinary Information
The Registrant has not been the subject of any disciplinary actions.
Item 10
Other Financial Industry Activities and Affiliations
A. Neither the Registrant, nor its representatives, are registered or have an application pending
to register, as a broker-dealer or a registered representative of a broker-dealer.
B. Neither the Registrant, nor its representatives, are registered or have an application pending
to register, as a futures commission merchant, commodity pool operator, a commodity
trading advisor, or a representative of the foregoing.
C. CPA Firm – Blueleaf Tax Services, LLC dba Huber, Quaranta & Associates
The Registrant shares office space and has a professional referral arrangement with Huber,
Quaranta & Associates, a third-party, accounting firm. Philip E. Huber, Sr does not have
an ownership interest in the accounting firm.
The Registrant may refer certain clients in need of accounting and tax services to Huber,
Quaranta & Associates. Services provided by Huber, Quaranta & Associates include the
following:
1. Accounting and bookkeeping;
2. Tax preparation; and
3. Tax planning.
Clients are under no obligation to engage Huber, Quaranta & Associates to provide
accounting services. The Registrant does not compensate the accounting firm for referrals
sent to it nor does the accounting firm compensate the Registrant for referrals directed to
the accounting firm.
Licensed Insurance Agency/Agents. The Registrant is separately licensed as an insurance
agency. Furthermore, certain of the Registrant’s representatives, in their individual
capacities, are licensed insurance agents. The Registrant and/or its representatives may
recommend the purchase of certain insurance-related products on a commission basis.
Clients can engage certain of Registrant’s representatives to purchase insurance products
on a commission basis.
Conflict of Interest: The recommendation by representatives of the Registrant that a client
purchase an insurance commission product presents a conflict of interest, as the receipt of
commissions may provide an incentive to recommend investment products based on
commissions to be received, rather than on a particular client’s need. No client is under any
obligation to purchase any commission products from representatives of the Registrant or
through the Registrant in its capacity as a licensed insurance agency. Clients are reminded
that they may purchase insurance products recommended by Registrant through other, non-
affiliated insurance agencies and/or agents.
D. The Registrant does not receive, directly or indirectly, compensation from investment
advisors that it recommends or selects for its clients.
13
Item 11
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
A. The Registrant maintains an investment policy relative to personal securities transactions.
This investment policy is part of Registrant’s overall Code of Ethics, which serves to
establish a standard of business conduct for all of Registrant’s representatives that is based
upon fundamental principles of openness, integrity, honesty and trust, a copy of which is
available upon request.
In accordance with Section 204A of the Investment Advisers Act of 1940, the Registrant
also maintains and enforces written policies reasonably designed to prevent the misuse of
material non-public information by the Registrant or any person associated with the
Registrant.
B. Neither the Registrant nor any related person of Registrant recommends, buys, or sells for
client accounts, securities in which the Registrant or any related person of Registrant has a
material financial interest.
C. The Registrant and/or representatives of the Registrant may buy or sell securities that are
also recommended to clients. This practice may create a situation where the Registrant
and/or representatives of the Registrant are in a position to materially benefit from the sale
or purchase of those securities. Therefore, this situation creates a conflict of interest.
Practices such as “scalping” (i.e., a practice whereby the owner of shares of a security
recommends that security for investment and then immediately sells it at a profit upon the
rise in the market price which follows the recommendation) could take place if the
Registrant did not have adequate policies in place to detect such activities. In addition, this
requirement can help detect insider trading, “front-running” (i.e., personal trades executed
prior to those of the Registrant’s clients) and other potentially abusive practices.
The Registrant has a personal securities transaction policy in place to monitor the personal
securities transactions and securities holdings of each of the Registrant’s “Access Persons”.
The Registrant’s securities transaction policy requires that an Access Person of the
Registrant must provide the Chief Compliance Officer or his/her designee with a written
report of the current securities holdings within ten (10) days after becoming an Access
Person. Additionally, each Access Person must provide the Chief Compliance Officer or
his/her designee with a written report of the Access Person’s current securities holdings at
least once each twelve (12) month period thereafter on a date the Registrant selects;
provided, however that at any time that the Registrant has only one Access Person, he or
she shall not be required to submit any securities report described above.
D. The Registrant and/or representatives of the Registrant may buy or sell securities, at or
around the same time as those securities are recommended to clients. This practice creates
a situation where the Registrant and/or representatives of the Registrant are in a position to
materially benefit from the sale or purchase of those securities. Therefore, this situation
creates a conflict of interest. The Registrant has a personal securities transaction policy in
place to monitor the personal securities transaction and securities holdings of each of
Registrant’s Access Persons.
14
Item 12
Brokerage Practices
A. In the event that the client requests that the Registrant recommend a broker-
dealer/custodian for execution and/or custodial services (exclusive of those clients that may
direct the Registrant to use a specific broker-dealer/custodian), Registrant generally
recommends that investment management accounts be maintained at Schwab. Prior to
engaging Registrant to provide investment management services, the client will be required
to enter into a formal Investment Advisory Agreement with Registrant setting forth the
terms and conditions under which Registrant shall manage the client's assets, and a separate
custodial/clearing agreement with each designated broker-dealer/custodian.
Factors that the Registrant considers in recommending Schwab (another broker-
dealer/custodian, investment platform and/or mutual fund sponsor) include historical
relationship with the Registrant, financial strength, reputation, execution capabilities,
pricing, research, and service. Although the commissions and/or transaction fees paid by
Registrant's clients shall comply with the Registrant's duty to obtain best execution, a client
can pay a commission that is higher than another qualified broker-dealer might charge to
effect the same transaction where the Registrant determines, in good faith, that the
commission/transaction fee is reasonable. In seeking best execution, the determinative
factor is not the lowest possible cost, but whether the transaction represents the best
qualitative execution, taking into consideration the full range of a broker-dealer’s services,
including the value of research provided, execution capability, commission rates, and
responsiveness. Accordingly, although Registrant will seek competitive rates, it may not
necessarily obtain the lowest possible commission rates for client account transactions. The
brokerage commissions or
transaction fees charged by the designated broker-
dealer/custodian are exclusive of, and in addition to, Registrant's investment management
fee. The Registrant’s best execution responsibility is qualified if securities that it purchases
for client accounts are mutual funds that trade at net asset value as determined at the daily
market close.
1. Research and Additional Benefits
Although not a material consideration when determining whether to recommend that a
client utilize the services of a particular broker-dealer/custodian, Registrant may
investment platform,
receive from Schwab (another broker-dealer/custodian,
unaffiliated investment manager, vendor, unaffiliated product/fund sponsor, or vendor)
without cost (and/or at a discount) support services and/or products, certain of which
assist the Registrant to better monitor and service client accounts maintained at such
institutions. Included within the support services that may be obtained by the
Registrant may be investment-related research, pricing information and market data,
discounted and/or gratis software and other technology that provide access to client
account data, compliance and/or practice management-related publications, discounted
or gratis consulting services, discounted and/or gratis attendance at conferences,
meetings, and other educational and/or social events, marketing support, computer
hardware and/or software and/or other products used by Registrant in furtherance of
its investment advisory business operations.
As indicated above, certain of the support services and/or products that may be received
may assist the Registrant in managing and administering client accounts. Others do not
directly provide such assistance, but rather assist the Registrant to manage and further
develop its business enterprise.
15
2. The Registrant does not receive referrals from broker-dealers.
3. The Registrant does not generally accept directed brokerage arrangements (when a
client requires that account transactions be effected through a specific broker-dealer).
In such client directed arrangements, the client will negotiate terms and arrangements
for their account with that broker-dealer, and Registrant will not seek better execution
services or prices from other broker-dealers or be able to "batch" the client's
transactions for execution through other broker-dealers with orders for other accounts
managed by Registrant. As a result, client may pay higher commissions or other
transaction costs or greater spreads, or receive less favorable net prices, on transactions
for the account than would otherwise be the case.
Please Note: In the event that the client directs Registrant to effect securities
transactions for the client's accounts through a specific broker-dealer, the client
correspondingly acknowledges that such direction may cause the accounts to incur
higher commissions or transaction costs than the accounts would otherwise incur had
the client determined to effect account transactions through alternative clearing
arrangements that may be available through Registrant. Higher transaction costs
adversely impact account performance. Please Also Note: Transactions for directed
accounts will generally be executed following the execution of portfolio transactions
for non-directed accounts.
B. To the extent that the Registrant provides investment management services to its clients,
the transactions for each client account generally will be effected independently, unless
the Registrant decides to purchase or sell the same securities for several clients at
approximately the same time. The Registrant may (but is not obligated to) combine or
“bunch” such orders to obtain best execution, to negotiate more favorable commission
rates or to allocate equitably among the Registrant’s clients differences in prices and
commissions or other transaction costs that might have been obtained had such orders been
placed independently. Under this procedure, transactions will be averaged as to price and
will be allocated among clients in proportion to the purchase and sale orders placed for
each client account on any given day. The Registrant shall not receive any additional
compensation or remuneration as a result of such aggregation.
Item 13
Review of Accounts
A. For those clients to whom Registrant provides investment supervisory services, account
reviews are conducted on an ongoing basis by Registrant’s representatives. All investment
supervisory and financial planning clients are advised that it remains their responsibility to
advise the Registrant of any changes in their investment objectives and/or financial
situation. All clients (in person or via telephone) are encouraged to review financial
planning issues, investment objectives and account performance with the Registrant on an
annual basis, as applicable.
B. The Registrant may conduct account reviews on an other than periodic basis upon the
occurrence of a triggering event, such as a change in client investment objectives and/or
financial situation, market corrections and client request.
16
C. Clients are provided with transaction confirmation notices and regular summary account
statements directly from the broker-dealer/custodian for the client accounts.
Item 14
Client Referrals and Other Compensation
A. As referenced in Item 12.A.1 above, the Registrant receives an economic benefit from
Schwab. The Registrant, without cost (and/or at a discount), may receive support services
and/or products from Schwab.
Registrant’s clients do not pay more for investment transactions effected and/or assets
maintained at Schwab as a result of this arrangement. There is no corresponding
commitment made by the Registrant to Schwab or any other entity to invest any specific
amount or percentage of client assets in any specific mutual funds, securities or other
investment products as a result of the above arrangement.
B. The Registrant does not compensate, directly or indirectly, any person, who is not a
supervised person for client referrals.
Item 15
Custody
The Registrant shall have the ability to have its advisory fee for each client debited by the
custodian on a quarterly basis. Clients are provided with transaction confirmation notices
and regular summary account statements directly from the broker-dealer/custodian for the
client accounts.
Please Note: To the extent that the Registrant provides clients with periodic account
statements or reports, the client is urged to compare any statement or report provided by
the Registrant with the account statements received from the account custodian. Please
Also Note: The account custodian does not verify the accuracy of the Registrant’s advisory
fee calculation.
Item 16
Investment Discretion
The client can determine to engage the Registrant to provide investment advisory services
on a discretionary basis. Prior to the Registrant acting on its discretionary authority over a
client’s account, the client shall be required to execute an Investment Advisory Agreement,
naming the Registrant as the client’s attorney and agent in fact, granting the Registrant full
authority to buy, sell, or otherwise effect investment transactions involving the assets in
the client’s name found in the discretionary account.
Clients who engage the Registrant on a discretionary basis may, at any time, impose
restrictions, in writing, on the Registrant’s discretionary authority (i.e. limit the
types/amounts of particular securities purchased for their account, exclude the ability to
purchase securities with an inverse relationship to the market, limit or proscribe the
Registrant’s use of margin, etc.).
17
Item 17
Voting Client Securities
A. The Registrant does not vote client proxies. Clients maintain exclusive responsibility for:
(1) directing the manner in which proxies solicited by issuers of securities owned by the
client shall be voted, and (2) making all elections relative to any mergers, acquisitions,
tender offers, bankruptcy proceedings or other type events pertaining to the client’s
investment assets.
HWA Aspire program clients are required to submit an Issuer Communication and Release
Information Form, or similarly named form, to be certain that they receive proxies and
corporate actions directly from the issuer of securities. The Registrant does not offer any
consulting assistance regarding proxy issues to client.
B. Clients will receive their proxies or other solicitations directly from their custodian. Clients
may contact the Registrant to discuss any questions they may have with a particular
solicitation.
Item 18
Financial Information
A. The Registrant does not solicit fees of more than $1,200, per client, six months or more in
advance.
B. The Registrant is unaware of any financial condition that is reasonably likely to impair its
ability to meet its contractual commitments relating to its discretionary authority over
certain client accounts.
C. The Registrant has not been the subject of a bankruptcy petition.
18
Item 1 Cover Page
A.
Philip E. Huber, Jr.
HWA Financial Group
ADV Part 2B, Brochure Supplement
Dated: March 20, 2026
Contact: Philip E. Huber, Jr., Chief Compliance Officer
3448 Ellicott Center Drive, Suite 101
Ellicott City, Maryland 21043
B.
This Brochure Supplement provides information about Philip E. Huber, Jr. that
supplements the HWA Financial Group Brochure; you should have received a copy of that
Brochure. Please contact Philip E. Huber, Jr., Chief Compliance Officer, if you did not
receive HWA Financial Group’s Brochure or if you have any questions about the contents
of this supplement.
Additional information about Philip E. Huber, Jr. is available on the SEC’s website at
www.adviserinfo.sec.gov
Item 2 Education Background and Business Experience
Philip E. Huber, Jr. was born in 1971. Mr. Huber graduated from Loyola College in 1993, with a
Bachelor of Science degree in Accounting. Mr. Huber has been employed as an investment adviser
representative of HWA Financial Group since October of 1999 and been President since January
of 2010.
Mr. Huber has been a CERTIFIED FINANCIAL PLANNER™ since 1998. The CERTIFIED
FINANCIAL PLANNER™, CFP® and federally registered CFP (collectively, the “CFP® marks”)
are professional certification marks granted in the United States by Certified Financial Planner
Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires
financial planners to hold CFP® certification. It is recognized in the United States and a number
of other countries for its (1) high standard of professional education; (2) stringent code of conduct
19
and standards of practice; and (3) ethical requirements that govern professional engagements with
clients. Currently, more than 79,000 individuals have obtained CFP® certification in the United
States.
To attain the right to use the CFP® marks, an individual must currently satisfactorily fulfill the
following requirements:
• Education – Complete an advanced college-level course of study addressing the financial
planning subject areas that CFP Board’s studies have determined as necessary for the
competent and professional delivery of financial planning services, and attain a Bachelor’s
Degree from a regionally accredited United States college or university (or its equivalent
from a foreign university). CFP Board’s financial planning subject areas include insurance
planning and risk management, employee benefits planning, investment planning, income
tax planning, retirement planning, and estate planning;
• Examination – Pass
the comprehensive CFP® Certification Examination. The
examination, administered in 6 hours, includes case studies and client scenarios designed
to test one’s ability to correctly diagnose financial planning issues and apply one’s
knowledge of financial planning to real world circumstances;
• Experience – Complete at least three years of full-time financial planning-related
experience (or the equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of
documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must currently complete the following ongoing education and
ethics requirements in order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years,
including two hours on the Code of Ethics and other parts of the Standards of Professional
Conduct, to maintain competence and keep up with developments in the financial planning
field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The
Standards prominently require that CFP® professionals provide financial planning services
at a fiduciary standard of care. This means CFP® professionals must provide financial
planning services in the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject
to CFP Board’s enforcement process, which could result in suspension or permanent revocation of
their CFP® certification.
Mr. Huber has held the designation of Certified Public Accountant (“CPA”) since 1994. CPAs
are licensed and regulated by their state boards of accountancy. While state laws and regulations
vary, the education, experience and testing requirements for licensure as a CPA generally include
minimum college education (typically 150 credit hours with at least a baccalaureate degree and
a concentration in accounting), minimum experience levels (most states require at least one year
of experience providing services that involve the use of accounting, attest, compilation,
management advisory, financial advisory, tax or consulting skills, all of which must be achieved
under the supervision of or verification by a CPA), and successful passage of the Uniform CPA
Examination. In order to maintain a CPA license, states generally require the completion of 40
20
hours of continuing professional education (CPE) each year (or 80 hours over a two-year period
or 120 hours over a three-year period). Additionally, all American Institute of Certified Public
Accountants (AICPA) members are required to follow a rigorous Code of Professional Conduct
which requires that they act with integrity, objectivity, due care, competence, fully disclose any
conflicts of interest (and obtain client consent if a conflict exists), maintain client confidentiality,
disclose to the client any commission or referral fees, and serve the public interest when
providing financial services. The vast majority of state boards of accountancy have adopted the
AICPA’s Code of Professional Conduct within their state accountancy laws or have created their
own.
In addition to the Code of Professional Conduct, AICPA members who provide personal financial
planning services are required to follow the Statement on Standards in Personal Financial
Planning Services (SSPFPS).
Item 3 Disciplinary Information
None.
Item 4 Other Business Activities
C. The supervised person is not actively engaged in any other investment-related
businesses or occupations.
D. Licensed Insurance Agent. Mr. Huber, in his individual capacity, is a licensed
insurance agent, and may recommend the purchase of certain insurance-related
products on a commission basis. Clients can engage Mr. Huber to purchase
insurance products on a commission basis. Conflict of Interest: The
recommendation by Mr. Huber that a client purchase an insurance commission
product presents a conflict of interest, as the receipt of commissions may provide
an incentive to recommend insurance products based on commissions to be
received, rather than on a particular client’s need. No client is under any obligation
to purchase any insurance commission products from Mr. Huber. Clients are
reminded that they may purchase insurance products recommended by Mr. Huber
through other, non-affiliated
insurance agents. The Registrant’s Chief
Compliance Officer, Philip E. Huber, Jr., remains available to address any
questions that a client or prospective client may have regarding the above
conflict of interest.
Item 5 Additional Compensation
None.
21
Item 6 Supervision
The Registrant provides investment advisory and supervisory services in
accordance with the Registrant’s policies and procedures manual. The primary
purpose of the Registrant’s Rule 206(4)-7 policies and procedures is to comply with
the supervision requirements of Section 203(e)(6) of the Investment Advisers Act
of 1940 (the “Act”). The Registrant’s Chief Compliance Officer, Philip E. Huber,
Jr., is primarily responsible for the implementation of the Registrant’s policies and
procedures and overseeing the activities of the Registrant’s supervised persons.
Should an employee, independent contractor, investment adviser representative, or
solicitor of the Registrant have any questions regarding the applicability/relevance
of the Act, the Rules thereunder, any section thereof, or any section of the policies
and procedures, he/she should address those questions with the Chief Compliance
Officer. Should a client have any questions regarding the Registrant’s supervision
or compliance practices, please contact Mr. Huber at (410) 696-4025
22
Item 1 Cover Page
A.
Joseph Ryan Geld
HWA Financial Group
ADV Part 2B, Brochure Supplement
Dated: March 20, 2026
Contact: Philip E. Huber, Jr., Chief Compliance Officer
3448 Ellicott Center Drive, Suite 101
Ellicott City, Maryland 21043
B.
This Brochure Supplement provides information about Joseph Ryan Geld that supplements
the HWA Financial Group Brochure; you should have received a copy of that Brochure.
Please contact Philip E. Huber, Jr., Chief Compliance Officer, if you did not receive HWA
Financial Group’s Brochure or if you have any questions about the contents of this
supplement.
Additional information about Joseph Ryan Geld is available on the SEC’s website at
www.adviserinfo.sec.gov
Item 2 Education Background and Business Experience
Joseph Ryan Geld was born in 1985. Mr. Geld graduated from Maryville College in 2007, with a
Bachelor of Arts degree and from Hood College in 2012 with a Master of Business Administration
degree. Mr. Geld has been employed as an investment adviser representative of HWA Financial
Group since September 2017. From November 2010 through September 2017, Mr. Geld was
employed as a Relationship Strategist with PNC Wealth Management.
Mr. Geld has been a CERTIFIED FINANCIAL PLANNER™ since 2017. The CERTIFIED
FINANCIAL PLANNER™, CFP® and federally registered CFP (collectively, the “CFP®
marks”) are professional certification marks granted in the United States by Certified Financial
Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires
financial planners to hold CFP® certification. It is recognized in the United States and a number
23
of other countries for its (1) high standard of professional education; (2) stringent code of conduct
and standards of practice; and (3) ethical requirements that govern professional engagements with
clients. Currently, more than 79,000 individuals have obtained CFP® certification in the United
States.
To attain the right to use the CFP® marks, an individual must currently satisfactorily fulfill the
following requirements:
• Education – Complete an advanced college-level course of study addressing the financial
planning subject areas that CFP Board’s studies have determined as necessary for the
competent and professional delivery of financial planning services, and attain a Bachelor’s
Degree from a regionally accredited United States college or university (or its equivalent
from a foreign university). CFP Board’s financial planning subject areas include insurance
planning and risk management, employee benefits planning, investment planning, income
tax planning, retirement planning, and estate planning;
• Examination – Pass
the comprehensive CFP® Certification Examination. The
examination, administered in 6 hours, includes case studies and client scenarios designed
to test one’s ability to correctly diagnose financial planning issues and apply one’s
knowledge of financial planning to real world circumstances;
• Experience – Complete at least three years of full-time financial planning-related
experience (or the equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of
documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must currently complete the following ongoing education and
ethics requirements in order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years,
including two hours on the Code of Ethics and other parts of the Standards of Professional
Conduct, to maintain competence and keep up with developments in the financial planning
field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The
Standards prominently require that CFP® professionals provide financial planning services
at a fiduciary standard of care. This means CFP® professionals must provide financial
planning services in the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject
to CFP Board’s enforcement process, which could result in suspension or permanent revocation of
their CFP® certification.
24
Mr. Geld has been a CFA® Charter Holder since 2014. CFA® designates an international
professional certificate that is offered by the CFA Institute.
The Chartered Financial Analyst (CFA) charter is a globally respected, graduate-level investment
credential established in 1962 and awarded by CFA Institute — the largest global association of
investment professionals.
There are currently more than 142,000 CFA charter holders working in 159 countries. To earn the
CFA charter, candidates must: (1) pass three sequential, six-hour examinations; (2) have at least
four years of qualified professional investment experience; (3) join CFA Institute as members; and
(4) commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics
and Standards of Professional Conduct.
High Ethical Standards
The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an
active professional conduct program, require CFA charter holders to:
• Place their clients’ interests ahead of their own
• Maintain independence and objectivity
• Act with integrity
• Maintain and improve their professional competence
• Disclose conflicts of interest and legal matters
Global Recognition
Passing the three CFA exams is a difficult feat that requires extensive study (successful candidates
report spending an average of 300 hours of study per level). Earning the CFA charter demonstrates
mastery of many of the advanced skills needed for investment analysis and decision making in
today’s quickly evolving global financial industry. As a result, employers and clients are
increasingly seeking CFA charterholders—often making the charter a prerequisite for
employment. Additionally, regulatory bodies in 38 countries/territories recognize the CFA charter
as a proxy for meeting certain licensing requirements, and more than 466 colleges and universities
around the world have incorporated a majority of the CFA Program curriculum into their own
finance courses.
Comprehensive and Current Knowledge
The CFA Program curriculum provides a comprehensive framework of knowledge for investment
decision making and is firmly grounded in the knowledge and skills used every day in the
investment profession. The three levels of the CFA Program test a proficiency with a wide range
of fundamental and advanced investment topics, including ethical and professional standards,
fixed-income and equity analysis, alternative and derivative investments, economics, financial
reporting standards, portfolio management, and wealth planning.
The CFA Program curriculum is updated every year by experts from around the world to ensure
that candidates learn the most relevant and practical new tools, ideas, and investment and wealth
management skills to reflect the dynamic and complex nature of the profession.
25
Item 3 Disciplinary Information
None.
Item 4 Other Business Activities
C. The supervised person is not actively engaged in any other investment-related
businesses or occupations.
D. Licensed Insurance Agent. Mr. Geld, in his individual capacity, is a licensed
insurance agent, and may recommend the purchase of certain insurance-related
products on a commission basis. Clients can engage Mr. Geld to purchase insurance
products on a commission basis. Conflict of Interest: The recommendation by Mr.
Geld that a client purchase an insurance commission product presents a conflict of
interest, as the receipt of commissions may provide an incentive to recommend
insurance products based on commissions to be received, rather than on a particular
client’s need. No client is under any obligation to purchase any insurance
commission products from Mr. Geld. Clients are reminded that they may purchase
insurance products recommended by Mr. Geld through other, non-affiliated
insurance agents. The Registrant’s Chief Compliance Officer, Philip E. Huber,
Jr., remains available to address any questions that a client or prospective
client may have regarding the above conflict of interest.
Item 5 Additional Compensation
None.
Item 6 Supervision
The Registrant provides investment advisory and supervisory services in accordance with the
Registrant’s policies and procedures manual. The primary purpose of the Registrant’s Rule
206(4)-7 policies and procedures is to comply with the supervision requirements of Section
203(e)(6) of the Investment Advisers Act of 1940 (the “Act”). The Registrant’s Chief Compliance
Officer, Philip E. Huber, Jr., is primarily responsible for the implementation of the Registrant’s
policies and procedures and overseeing the activities of the Registrant’s supervised persons.
Should an employee, independent contractor, investment adviser representative, or solicitor of the
Registrant have any questions regarding the applicability/relevance of the Act, the Rules
thereunder, any section thereof, or any section of the policies and procedures, he/she should
address those questions with the Chief Compliance Officer. Should a client have any questions
regarding the Registrant’s supervision or compliance practices, please contact Mr. Huber at (410)
696-4025.
26
Item 1 Cover Page
A.
Daniel S. Pereira
HWA Financial Group
ADV Part 2B, Brochure Supplement
Dated: March 20, 2026
Contact: Philip E. Huber, Jr., Chief Compliance Officer
3448 Ellicott Center Drive, Suite 101
Ellicott City, Maryland 21043
B.
This Brochure Supplement provides information about Daniel S. Pereira that supplements
the HWA Financial Group Brochure; you should have received a copy of that Brochure.
Please contact Philip E. Huber, Jr., Chief Compliance Officer, if you did not receive HWA
Financial Group’s Brochure or if you have any questions about the contents of this
supplement.
Additional information about Daniel S. Pereira is available on the SEC’s website at
www.adviserinfo.sec.gov
Item 2 Education Background and Business Experience
Daniel Spencer Pereira was born in 1992. Mr. Pereira graduated from Salisbury University in
2015, with a bachelor’s degree in finance. Mr. Pereira has been employed as an investment adviser
representative of HWA Financial Group since November 2023. From June 2015 through February
2022, Mr. Pereira was employed as a Financial Advisor with Merrill Lynch Wealth Management.
From February 2022 through October 2023, Mr. Pereira was employed as a Financial Advisor with
WMS Partners and Signature Estate and Investment Advisors.
Mr. Pereira has been a CERTIFIED FINANCIAL PLANNER™ since 2017. The CERTIFIED
FINANCIAL PLANNER™, CFP® and federally registered CFP (collectively, the “CFP®
marks”) are professional certification marks granted in the United States by Certified Financial
Planner Board of Standards, Inc. (“CFP Board”).
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The CFP® certification is a voluntary certification; no federal or state law or regulation requires
financial planners to hold CFP® certification. It is recognized in the United States and a number
of other countries for its (1) high standard of professional education; (2) stringent code of conduct
and standards of practice; and (3) ethical requirements that govern professional engagements with
clients. Currently, more than 79,000 individuals have obtained CFP® certification in the United
States.
To attain the right to use the CFP® marks, an individual must currently satisfactorily fulfill the
following requirements:
• Education – Complete an advanced college-level course of study addressing the financial
planning subject areas that CFP Board’s studies have determined as necessary for the
competent and professional delivery of financial planning services, and attain a Bachelor’s
Degree from a regionally accredited United States college or university (or its equivalent
from a foreign university). CFP Board’s financial planning subject areas include insurance
planning and risk management, employee benefits planning, investment planning, income
tax planning, retirement planning, and estate planning;
• Examination – Pass
the comprehensive CFP® Certification Examination. The
examination, administered in 6 hours, includes case studies and client scenarios designed
to test one’s ability to correctly diagnose financial planning issues and apply one’s
knowledge of financial planning to real world circumstances;
• Experience – Complete at least three years of full-time financial planning-related
experience (or the equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of
documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must currently complete the following ongoing education and
ethics requirements in order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years,
including two hours on the Code of Ethics and other parts of the Standards of Professional
Conduct, to maintain competence and keep up with developments in the financial planning
field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The
Standards prominently require that CFP® professionals provide financial planning services
at a fiduciary standard of care. This means CFP® professionals must provide financial
planning services in the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject
to CFP Board’s enforcement process, which could result in suspension or permanent revocation of
their CFP® certification.
Item 3 Disciplinary Information
None.
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Item 4 Other Business Activities
C. The supervised person is not actively engaged in any other investment-related
businesses or occupations.
Item 5 Additional Compensation
None.
Item 6 Supervision
The Registrant provides investment advisory and supervisory services in accordance with the
Registrant’s policies and procedures manual. The primary purpose of the Registrant’s Rule
206(4)-7 policies and procedures is to comply with the supervision requirements of Section
203(e)(6) of the Investment Advisers Act of 1940 (the “Act”). The Registrant’s Chief Compliance
Officer, Philip E. Huber, Jr., is primarily responsible for the implementation of the Registrant’s
policies and procedures and overseeing the activities of the Registrant’s supervised persons.
Should an employee, independent contractor, investment adviser representative, or solicitor of the
Registrant have any questions regarding the applicability/relevance of the Act, the Rules
thereunder, any section thereof, or any section of the policies and procedures, he/she should
address those questions with the Chief Compliance Officer. Should a client have any questions
regarding the Registrant’s supervision or compliance practices, please contact Mr. Huber at (410)
696-4025.
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Privacy Policy
HWA Financial Group does not disclose any non-public, personal information (such as name, address or
tax identification number) about its clients or former clients to anyone except as permitted by applicable
law or required by regulation. We maintain physical safeguards to protect such unauthorized disclosure
and will notify you of our policies and practices in this regard on an annual basis or at any time at which
there is a material change in our policies which would require your consent. HWA Financial Group does
not sell customer lists. Even if you are no longer a client of HWA Financial Group, our Privacy Policy
will continue to apply to you. To conduct regular business, we may collect non-public personal
information from sources such as: (a) information provided by you on applications or other forms you
provide to us; and/or (b) information about your investment and securities transactions.
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