Idle Hill Advisors LLC

Idle Hill Advisors LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Idle Hill Advisors LLC. If you have any questions about the contents of this brochure, please contact us at (864) 297-6125 or by email at: pate@idlehill.capital. 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 Idle Hill Advisors LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Idle Hill Advisors LLC’s CRD number is: 317040. 201 Roper Creek Drive Greenville, SC 29615 (864) 297-6125 pate@idlehill.capital Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 06/18/2026  Item 2: Material Changes Pursuant to State and SEC rules, Idle Hill Advisors LLC will ensure that clients receive a summary of any material changes to this and subsequent disclosure brochures within 120 days after the Firm’s fiscal year end, December 31. This means that if there were any material changes over the past year, clients will receive a summary of those changes no later than April 30. At that time, Idle Hill Advisors LLC will also offer a copy of its most current disclosure brochure and may also provide other ongoing disclosure information about material changes as necessary. If there are no material changes over the past year, no notices will be sent. Clients and prospective clients can always receive the most current disclosure brochure for Idle Hill Advisors LLC at any time by contacting their investment advisor representative. Since the last annual update on March 24, 2026, the material changes are as follows: Edward Storer is no longer the owner of Idle Hill Advisors, LLC. IME Irrevocable Trust is now the majority owner. 1 | P a g e  Item 3: Table of Contents Contents Item 2: Material Changes .............................................................................................. 1 Item 3: Table of Contents .............................................................................................. 2 Item 4: Advisory Business ............................................................................................. 3 Item 5: Fees and Compensation .................................................................................... 5 Item 6: Performance-Based Fees and Side-By-Side Management .............................. 7 Item 7: Types of Clients ................................................................................................. 8 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ......................... 9 Item 9: Disciplinary Information ................................................................................ 18 Item 10: Other Financial Industry Activities and Affiliations .................................. 19 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................................................................................................... 21 Item 12: Brokerage Practices ...................................................................................... 23 Item 13: Review of Accounts ....................................................................................... 25 Item 14: Client Referrals and Other Compensation .................................................. 26 Item 15: Custody .......................................................................................................... 28 Item 16: Investment Discretion .................................................................................. 29 Item 17: Voting Client Securities (Proxy Voting) ....................................................... 30 Item 18: Financial Information ................................................................................... 31 2 | P a g e  Item 4: Advisory Business A. Description of the Advisory Firm Idle Hill Advisors LLC (hereinafter “IHAL”) is a Limited Liability Company organized in the State of South Carolina. The firm was formed in September 2021 and became registered as an investment adviser in 2022. The principal owners are Henry Pate Hasty and the IME Trust. B. Types of Advisory Services Portfolio Management Services IHAL offers ongoing portfolio management services inclusive of financial planning services based on the individual goals, objectives, time horizon, and risk tolerance of each client. IHAL creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • • • Investment strategy Asset allocation Risk tolerance • • • Personal investment policy Asset selection Regular portfolio monitoring IHAL evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. IHAL will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. In addition, IHAL provides portfolio management services on assets held away from IHAL although IHAL will not have discretionary authority or any trading authority with respect to these assets. IHAL seeks to make investment decisions in accordance with the fiduciary duties owed to its clients and without consideration of IHAL’s economic, investment or other financial interests. To meet its fiduciary obligations, IHAL attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, IHAL’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is IHAL’s policy to 3 | P a g e  allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. IHAL offers recommendations on ESG (Environmental, Social and Governance issues) and Faith-Based investing for clients who require such objectives and outcomes. Selection of Other Advisers IHAL may direct clients to third-party investment advisers. Before selecting other advisers for clients, IHAL will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where IHAL is recommending the adviser to clients. Services Limited to Specific Types of Investments IHAL generally limits its investment advice to fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities and venture capital funds. IHAL may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions IHAL will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by IHAL on behalf of the client. IHAL may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. IHAL does not participate in wrap fee programs. E. Assets Under Management IHAL has the following assets under management: Discretionary Amount Non-Discretionary Amt. Date Calculated $107,447,661 $31,351 Dec. 31, 2025 4 | P a g e  Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees IHAL uses an average of the daily balance in the client's account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. IHAL charges a tiered blended rate determined by the total assets under our management for a client, their spouse, and any entity or trust accounts that they control. IHAL will receive its standard fee on top of the fee paid to any third-party adviser. Total Assets Under Management Annual Fees Below $500,000 $500,001 – $2,000,000 $2,000,001 - $5,000,000 $5,000,001 – AND UP 1.45% 1.25% 1.00% 0.75% For example, if a client had $2,500,000 (between all their accounts), their fee would be 1.45% on the first $500,000, 1.25% on the amount between $500,000 and $2,000,000, and 1.00% on the remaining $500,000, for a total fee of 1.24%. IHAL may, by agreement with a client, waive the fee for certain accounts. If IHAL has agreed to do so, IHAL will list those accounts in each client contract, or in another contract addendum signed by IHAL and the client. If IHAL has agreed to waive its fee on an account in this way, then the balance of that account will still be considered when determining the total assets under management for billing the remaining accounts. So in the example above, if $1,000,000 of the client’s assets were in accounts where we had agreed to waive our fee, then we would still only charge 1.24% on the remaining accounts. (If we only calculated the fee on $1,500,000, then the total fee would be 1.32%.) IHAL may, by agreement with a client, charge a flat fee instead of this tiered rate. Those fees will not exceed 1.45% per year. The fee for portfolio management services on assets held away from IHAL is negotiable and will not exceed 1.45% of the assets advised per year. These fees are generally negotiable, and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of IHAL's fees within five business days of signing the 5 | P a g e  Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. Selection of Other Advisers Fees IHAL may direct clients to third-party investment advisers. IHAL will receive its standard fee on top of the fee paid to any third-party adviser. The fees shared are negotiable and will not exceed any limit imposed by any regulatory agency. The notice of termination requirement and payment of fees for third-party investment advisers will depend on the specific third-party adviser selected. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a monthly basis. IHAL will bill clients for fees on assets held away. Fees are paid in arrears. Payment of Selection of Other Advisers Fees The timing, frequency, and method of paying fees for selection of third-party managers will depend on the specific third-party adviser selected and will be disclosed to the client prior to entering into a relationship with the third-party advisor. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by IHAL. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees IHAL collects its fees in arrears. It does not collect fees in advance. E. Outside Compensation For the Sale of Securities to Clients Neither IHAL nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds. 6 | P a g e  Item 6: Performance-Based Fees and Side-By-Side Management IHAL does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. 7 | P a g e  Item 7: Types of Clients IHAL generally provides advisory services to the following types of clients: • Individuals • High-Net-Worth Individuals • Corporations or Business Entities There is no account minimum for any of IHAL’s services. 8 | P a g e  Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis IHAL’s methods of analysis include Cyclical analysis, Fundamental analysis and Quantitative analysis. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Faith-Based Investing: Idle Hill provides clients the opportunity to support their religious values by investing in faith-based funds and securities that have been reviewed by third-party analysts. Investment Strategies Long-Term Purchases Long-term purchases are securities that are purchased with the expectation that the value of those securities will grow over a relatively long period, generally greater than one year. Long-term purchases may be affected by unforeseen changes in the company in which a client is invested or in the overall market. Long term trading is designed to capture market rates of both return and risk. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Due to its nature, the long-term strategy can expose clients to various other types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include, but are not limited to, inflation (purchasing power) risk, interest rate risk, economic risk, and political/regulatory risk. Short-Term Purchases Short-term purchases are securities that are purchased with the expectation that they will be sold within a relatively short period of time, generally less than one 9 | P a g e  year, to take advantage of the securities’ short-term price fluctuations. Short-term trading generally holds greater risk. Frequent trading can affect investment performance due to increased brokerage fees and other transaction costs and taxes. Strategic Asset Allocation Asset allocation is a combination of several different types of investments; typically, this includes stocks, bonds, and cash equivalents among various asset classes to achieve diversification. The objective of asset allocation is to manage risk and market exposure while still positioning a portfolio to meet financial objectives. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Cyclical analysis: This method assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Fundamental analysis: This method concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Quantitative analysis: This method uses models that may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Faith-Based Investing: When reviewing and recommending faith-based securities, Idle Hill applies the same investment methodology as any other portfolio, with the additional requirement that the securities must be reported as “clean” by third party analysts who review companies and funds on a moral or religious basis. This limits the available universe of securities, and some strategies (such as options strategies that require high levels of liquidity) may not be perfectly replicated. These types of investments may trail broad indices; therefore, clients may sacrifice 10 | P a g e  potential returns for moral concerns. Clients may also take on additional concentration risk if a smaller number of “clean” positions meet our normal investment criteria for a given strategy. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Investing inherently involves risk up to and including loss of the principal sum. Further, past performance of any security is not necessarily indicative of future results. Therefore, future performance of any specific investment or investment strategy based on past performance should not be assumed as a guarantee. Idle Hill does not provide any representation or guarantee that the financial goals of clients will be achieved. The potential return or gain and potential risk or loss of an investment varies, generally speaking, with the type of product invested in. Below is an overview of the types of products available on the market and the associated risks of each: General Risks. Investing in securities always involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives can or will be met. Past performance is in no way an indication of future performance. We also cannot assure that third parties will satisfy their obligations in a timely manner or perform as expected or marketed. General Market Risk. Investment returns will fluctuate based upon changes in the value of the portfolio securities. Certain securities held may be worth less than the price originally paid for them, or less than they were worth at an earlier time. 11 | P a g e  Common Stocks. Investments in common stocks, both directly and indirectly through investment in shares of ETFs, may fluctuate in value in response to many factors, including, but not limited to, the activities of the individual companies, general market and economic conditions, interest rates, and specific industry changes. Such price fluctuations subject certain strategies to potential losses. During temporary or extended bear markets, the value of common stocks will decline, which could also result in losses for each strategy. Portfolio Turnover Risk. High rates of portfolio turnover could lower performance of an investment strategy due to increased costs and may result in the realization of capital gains. If an investment strategy realizes capital gains when it sells its portfolio investments, it will increase taxable distributions to you. High rates of portfolio turnover in a given year would likely result in short-term capital gains and under current tax law you would be taxed on short-term capital gains at ordinary income tax rates, if held in a taxable account. Non-Diversified Strategy Risk. Some investment strategies may be non- diversified (e.g., investing a greater percentage of portfolio assets in a particular issuer and owning fewer securities than a diversified strategy). Accordingly, each such strategy is subject to the risk that a large loss in an individual issuer will cause a greater loss than it would if the strategy held a larger number of securities or smaller positions sizes. Model Risk. Financial and economic data series are subject to regime shifts, meaning past information may lack value under future market conditions. Models are based upon assumptions that may prove invalid or incorrect under many market environments. We may use certain model outputs to help identify market opportunities and/or to make certain asset allocation decisions. There is no guarantee that any model will work under all market conditions. For this reason, we include model-related results as part of our investment decision process but we often weigh professional judgment more heavily in making trades or asset allocations. ETF Risks, including Net Asset Valuations and Tracking Error. An ETF's performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because 1) the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or for the securities held by the ETF 12 | P a g e  may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. Certain ETF strategies may from time to time include the purchase of fixed income, commodities, foreign securities, American Depository Receipts, or other securities for which expenses and commission rates could be higher than normally charged for exchange-traded equity securities, and for which market quotations or valuation may be limited or inaccurate. Clients should be aware that to the extent they invest in ETF securities they will pay two levels of advisory compensation – advisory fees charged by Adviser plus any advisory fees charged by the issuer of the ETF. This scenario may cause a higher advisory cost (and potentially lower investment returns) than if a Client purchased the ETF directly. An ETF typically includes embedded expenses that may reduce the ETF's net asset value, and therefore directly affect the ETF's performance and indirectly affect a Client’s portfolio performance or an index benchmark comparison. Expenses of the ETF may include investment advisor management fees, custodian fees, brokerage commissions, and legal and accounting fees. ETF expenses may change from time to time at the sole discretion of the ETF issuer. ETF tracking error and expenses may vary. Inflation, Currency, and Interest Rate Risks. Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of an investor’s future interest payments and principal. Inflation also generally leads to higher interest rates, which in turn may cause the value of many types of fixed income investments to decline. In addition, the relative value of the U.S. dollar-denominated assets primarily managed by Adviser may be affected by the risk that currency devaluations affect Client purchasing power. Liquidity Risk. Liquidity is the ability to readily convert an investment into cash to prevent a loss, realize an anticipated profit, or otherwise transfer funds out of the particular investment. Generally, investments are more liquid if the investment has an established market of purchasers and sellers, such as a stock or bond listed on a national securities exchange. Conversely, investments that do not have an established market of purchasers and sellers may be considered illiquid. Your investment in illiquid investments may be for an indefinite time, because of the lack of purchasers willing to convert your investment to cash or other assets. Legislative and Tax Risk. Performance may directly or indirectly be affected by government legislation or regulation, which may include, but is not limited to: 13 | P a g e  changes in investment advisor or securities trading regulation; change in the U.S. government’s guarantee of ultimate payment of principal and interest on certain government securities; and changes in the tax code that could affect interest income, income characterization and/or tax reporting obligations, particularly for options, swaps, master limited partnerships, Real Estate Investment Trust, Exchange Traded Products/Funds/Securities. We do not engage in tax planning, and in certain circumstances a Client may incur taxable income on their investments without a cash distribution to pay the tax due. Clients and their personal tax advisors are responsible for how the transactions in their account are reported to the IRS or any other taxing authority. Foreign Investing and Emerging Markets Risk. Foreign investing involves risks not typically associated with U.S. investments, and the risks maybe exacerbated further in emerging market countries. These risks may include, among others, adverse fluctuations in foreign currency values, as well as adverse political, social, and economic developments affecting one or more foreign countries. In addition, foreign investing may involve less publicly available information and more volatile or less liquid securities markets, particularly in markets that trade a small number of securities, have unstable governments, or involve limited industry. Investments in foreign countries could be affected by factors not present in the U.S., such as restrictions on receiving the investment proceeds from a foreign country, foreign tax laws or tax withholding requirements, unique trade clearance or settlement procedures, and potential difficulties in enforcing contractual obligations or other legal rules that jeopardize shareholder protection. Foreign accounting may be less transparent than U.S. accounting practices and foreign regulation may be inadequate or irregular. Information Security Risk. We may be susceptible to risks to the confidentiality and security of its operations and proprietary and customer information. Information risks, including theft or corruption of electronically stored data, denial of service attacks on our website or websites of our third-party service providers, and the unauthorized release of confidential information are a few of the more common risks faced by us and other investment advisers. Data security breaches of our electronic data infrastructure could have the effect of disrupting our operations and compromising our customers' confidential and personally identifiable information. Such breaches could result in an inability of us to conduct business, potential losses, including identity theft and theft of investment funds from customers, and other adverse consequences to customers. We have taken and will continue to take steps to detect and limit the risks associated with these threats. 14 | P a g e  Tax Risks. Tax laws and regulations applicable to an account with Adviser may be subject to change and unanticipated tax liabilities may be incurred by an investor as a result of such changes. In addition, customers may experience adverse tax consequences from the early assignment of options purchased for a customer's account. Customers should consult their own tax advisers and counsel to determine the potential tax-related consequences of investing. Advisory Risk. There is no guarantee that our judgment or investment decisions on behalf of any particular account will necessarily produce the intended results. Our judgment may prove to be incorrect, and an account might not achieve its investment objectives. In addition, it is possible that we may experience computer equipment failure, loss of internet access, viruses, or other events that may impair access to accounts’ custodians’ software. Adviser and its representatives are not responsible to any account for losses unless caused by Adviser breaching our fiduciary duty. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in 15 | P a g e  zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on later in the future. Annuities are contracts issued by a life insurance company designed to meet requirements or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a well-diversified investment in commodities can be uncertain. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option writing also involves risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Dependence on Key Employees. An account’s success depends, in part, upon the ability of our key professionals to achieve the targeted investment goals. The loss of 16 | P a g e  any of these key personnel could adversely impact the ability to achieve such investment goals and objectives of the account. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 17 | P a g e  Item 9: Disciplinary Information A. Criminal or Civil Actions Management individual has civil actions detailed in the Advisor’s ADV Part 2B, which can be found via https://adviserinfo.sec.gov/. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. 18 | P a g e  Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither IHAL nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither IHAL nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Certain investment adviser representatives at our Firm are also licensed insurance agents and may place insurance business through Insurance Made Easy, an insurance agency owned by Ed Storer. As a result, Mr. Storer and other advisers will receive commissions or other compensation from the sale of insurance. This creates a conflict of interest because there is an incentive to recommend insurance products based on compensation rather than client needs. Idle Hill Advisors LLC addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. Idle Hill Advisors LLC periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. No client is ever under any obligation to purchase any insurance product. Insurance products recommended by Idle Hill Advisors LLC’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. Henry Pate Hasty is an associate with Wealth Training Academy LLC, which offers marketing, advertising, and business coaching. From time to time, he may offer clients advice or products from this activity and clients should be aware that this service may involve a conflict of interest. Idle Hill Advisors LLC always acts in the 19 | P a g e  best interest of the client and clients always have the right to decide whether or not to utilize the services of any Idle Hill Advisors LLC representative in such individual’s outside capacities. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections IHAL may direct clients to third-party investment advisers. Clients will pay IHAL its standard fee in addition to the standard fee for the advisers to which it directs those clients. The fees will not exceed any limit imposed by any regulatory agency. IHAL will always act in the best interests of the client, including when determining which third-party investment adviser to recommend to clients. IHAL will ensure that all recommended advisers are exempt, licensed or notice filed in the states in which IHAL is recommending them to clients. 20 | P a g e  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics IHAL has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. IHAL's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests IHAL does not recommend that clients buy or sell any security in which a related person to IHAL or IHAL has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of IHAL may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of IHAL to buy or sell the same securities before or after recommending the same securities to clients, resulting in representatives profiting from the recommendations they provide to clients. Such transactions may create a conflict of interest. IHAL will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are bought or sold. When the same securities are being bought or sold, IHAL employees will either transact clients’ transactions before their own or will transact alongside clients’ transactions in block or bunch trades. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of IHAL may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of IHAL to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations 21 | P a g e  they provide to clients. Such transactions may create a conflict of interest; however, IHAL will never engage in trading that operates to the client’s disadvantage if representatives of IHAL buy or sell securities at or around the same time as clients. 22 | P a g e  Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on IHAL’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and IHAL may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in IHAL's research efforts. IHAL will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. IHAL will require clients to use Charles Schwab Institutional, a division of Charles Schwab & Co., Inc. (“Charles Schwab”) Member FINRA/SIPC. 1. Research and Other Soft-Dollar Benefits While IHAL has no formal soft dollars program in which soft dollars are used to pay for third party services, as a registered investment advisor we have access to research products and services from your account custodian and/or another brokerage firm. See Item 14 for further information. 2. Brokerage for Client Referrals IHAL receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use IHAL will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts If IHAL buys or sells the same securities on behalf of more than one client, it might, but would be under no obligation to, aggregate or bunch, to the extent permitted by applicable law and regulations, the securities to be purchased or sold for multiple clients in order to seek more favorable prices, lower brokerage commissions or more efficient execution. In such case, IHAL would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; 23 | P a g e  provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. IHAL would determine the appropriate number of shares to place with brokers and will select the appropriate brokers consistent with IHAL’s duty to seek best execution, except for those accounts with specific brokerage direction (if any). 24 | P a g e  Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for IHAL's advisory services provided on an ongoing basis are reviewed at least annually by Henry Pate Hasty, Managing Member and Chief Compliance Officer, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at IHAL are assigned to this reviewer. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of IHAL's advisory services provided on an ongoing basis will receive a monthly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. 25 | P a g e  Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) IHAL participates in the institutional advisor program (the "Program") offered by Charles Schwab. Charles Schwab offers to independent investment advisor services which include custody of securities, trade execution, clearance and settlement of transactions. IHAL receives some benefits from Charles Schwab through its participation in the Program. As disclosed above, IHAL participates in Charles Schwab's institutional advisor program and IHAL may recommend Charles Schwab to clients for custody and brokerage services. There is no direct link between IHAL's participation in the Program and the investment advice it gives to its clients, although IHAL receives economic benefits through its participation in the Program that are typically not available to Charles Schwab retail investors. These benefits include the following products and services (provided without cost or at a discount): receipt of duplicate client statements and confirmations; research related products and tools; consulting services; access to a trading desk serving IHAL participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts); the ability to have IHAL's fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to IHAL by third party vendors. Charles Schwab may also pay for business consulting and professional services received by IHAL's related persons. Some of the products and services made available by Charles Schwab through the Program may benefit IHAL but may not benefit its client accounts. These products or services may assist IHAL in managing and administering client accounts, including accounts not maintained at Charles Schwab. Other services made available by Charles Schwab are intended to help IHAL manage and further develop its business enterprise. The benefits received by IHAL or its personnel through participation in the Program do not depend on the amount of brokerage transactions directed to Charles Schwab. As part of its fiduciary duties to clients, IHAL endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by IHAL or its related persons 26 | P a g e  in and of itself creates a conflict of interest and may indirectly influence the IHAL's choice of Charles Schwab for custody and brokerage services. B. Compensation to Non – Advisory Personnel for Client Referrals IHAL does not directly or indirectly compensate any person who is not advisory personnel for client referrals. 27 | P a g e  Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, IHAL will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Custody is also disclosed in Form ADV because IHAL has authority to transfer money from client account(s), which constitutes a standing letter of authorization (SLOA). Accordingly, IHAL will follow the safeguards specified by the SEC rather than undergo an annual audit. 28 | P a g e  Item 16: Investment Discretion IHAL provides discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, IHAL generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, IHAL’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to IHAL). 29 | P a g e  Item 17: Voting Client Securities (Proxy Voting) IHAL will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. 30 | P a g e  Item 18: Financial Information A. Balance Sheet IHAL neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither IHAL nor its management has any financial condition that is likely to reasonably impair IHAL’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years IHAL has not been the subject of a bankruptcy petition in the last ten years. 31 | P a g e