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Brochure
Form ADV Part 2A
Item 1 - Cover Page
CRD# 144516
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
www.NHoffmanandCo.com
October 15, 2025
This Brochure provides information about the qualifications and business practices of Nicholas
Hoffman & Company, LLC. If you have any questions about the contents of this Brochure, please
contact us at (404) 815-5050 or info@nhoffmanandco.com. The information in this Brochure has
not been approved or verified by the United States Securities and Exchange Commission or by any
state authority.
Nicholas Hoffman & Company, LLC is an investment advisory firm registered with the appropriate
regulatory authority. Registration does not imply a certain level of skill or training. Additional
www.AdviserInfo.sec.gov
information about Nicholas Hoffman & Company, LLC also is available on the SEC’s website at
.
Item 2 - Material Changes
Registered Investment Advisers are required to use the Brochure to inform clients of the nature of
advisory services provided, types of clients served, fees charged, potential conflicts of interest and
other information. The Brochure requirements include providing a Summary of Material Changes
(the “Summary”) reflecting any material changes to our policies, practices, or conflicts of interest
made since our last required “annual update” filing. In the event of any material changes, such
Summary is provided to all clients within 120 days of our fiscal year-end. Our last annual update was
filed on March 14, 2025. The complete Brochure is available to clients at any time upon request.
Item 3 - Table of Contents
Page
Item 1 - Cover Page ............................................................................................................................................................ 1
Item 2 - Material Changes................................................................................................................................................ 1
Item 3 - Table of Contents ............................................................................................................................................... 2
Item 4 - Advisory Business ............................................................................................................................................. 3
Item 5 - Fees and Compensation .................................................................................................................................. 7
Item 6 - Performance-Based Fees and Side-By-Side Management ................................................................ 9
Item 7 - Types of Clients ................................................................................................................................................ 10
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ...................................................... 10
Item 9 - Disciplinary Information .............................................................................................................................. 14
Item 10 - Other Financial Industry Activities and Affiliations ....................................................................... 14
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 ...................................................................................................................................... 18
Item 14 - Client Referrals and Other Compensation .......................................................................................... 19
Item 15 - Custody .............................................................................................................................................................. 19
Item 16 - Investment Discretion ................................................................................................................................. 19
Item 17 - Voting Client Securities .............................................................................................................................. 19
Item 18 - Financial Information .................................................................................................................................. 19
Brochure Supplements…………………..………………………...………….……………………………………… Exhibit A
Page 2
Item 4 - Advisory Business
Brochure Supplements
General Information
Nicholas Hoffman & Company, LLC (“we,” “us” or “NHCO”) was formed in 2007 and provides financial
planning and portfolio management services to its clients.
Exhibit
A
Nicholas J. Hoffman is the sole principal owner of NHCO. Please see
,
, for more information on Mr. Hoffman and other individuals who formulate investment advice and
have direct contact with clients or have discretionary authority over client accounts.
As of December 31, 2024, we managed $5,826,920,988 on a discretionary basis, and $1,334,250,873
of assets on a non-discretionary basis.
SERVICES OFFERED
At the outset of each client relationship, we spend time with the client, asking questions, discussing
the client’s investment experience and financial circumstances, and broadly identifying major goals
of the client.
Clients may elect to retain us to prepare a full financial plan. This detailed analysis is presented to
the client for consideration. In most cases, clients subsequently retain us to manage the investment
portfolio on an ongoing basis.
For those financial planning clients making this election, and for other clients who do not need
financial planning but retain us for portfolio management services, based on all the information
initially gathered, we generally develop with each client:
•
•
a financial outline for the client based on the client’s financial circumstances and goals, and
the client’s risk tolerance level (the “Financial Profile” or “Profile”);
the client’s investment objectives and guidelines (the “Investment Plan” or “Plan”).
The Financial Profile is a reflection of the client’s current financial picture and a look to the future
goals of the client. The Investment Plan outlines the types of investments we will make or
recommend on behalf of the client to meet those goals. The Profile and the Plan are discussed
regularly with each client but are not necessarily written documents.
Financial Planning
One of the services offered by us is financial planning, described below. This service may be provided
as a stand-alone service or may be coupled with ongoing portfolio management.
Financial planning may include advice that addresses one or more areas of a client's financial
situation, such as estate planning, risk management, budgeting and cash flow controls, retirement
planning, education funding, philanthropic planning, and investment portfolio design. Depending on
a client’s particular situation, financial planning may include some or all of the following:
•
•
•
Gathering factual information concerning the client's personal and financial situation;
Assisting the client in establishing financial goals and objectives;
Analyzing the client's present situation and anticipated future activities in light of the client's
financial goals and objectives;
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•
•
•
•
•
Identifying problems foreseen in the accomplishment of these financial goals and objectives
and offering alternative solutions to the problems;
Making recommendations to help achieve retirement plan goals and objectives;
Designing an investment portfolio to help meet the goals and objectives of the client;
Providing estate planning, and
Reviewing goals and objectives and measuring progress toward these goals.
Once financial planning advice is given, the client may choose to have us implement the client’s
financial plan and manage the investment portfolio on an ongoing basis. However, the client is under
no obligation to act upon any of the recommendations made by us under a financial planning
engagement and/or engage the services of any recommended professional.
Portfolio Management
As described above, at the beginning of a client relationship, we meet with the client, gather
information, and perform research and analysis as necessary to develop the client’s Investment Plan.
The Investment Plan will be updated from time to time when requested by the client, or when
determined to be necessary or advisable by us based on updates to the client’s financial or other
circumstances.
To implement the client’s Investment Plan, we will manage the client’s investment portfolio on a
discretionary basis or a non-discretionary basis. As a discretionary investment adviser, we will have
the authority to supervise and direct the portfolio without prior consultation with the client. Under
a non-discretionary arrangement, clients must be contacted prior to the execution of any trade in the
account(s) under management. This may result in a delay in executing recommended trades, which
could adversely affect the performance of the portfolio. In a non-discretionary arrangement, the
client retains the responsibility for the final decision on all actions taken with respect to the portfolio.
Notwithstanding the foregoing, clients may impose certain written restrictions on us in the
management of their investment portfolios, such as prohibiting the inclusion of certain types of
investments in an investment portfolio or prohibiting the sale of certain investments held in the
account at the commencement of the relationship. Each client should note, however, that restrictions
imposed by a client may adversely affect the composition and performance of the client’s investment
portfolio. Each client should also note that his or her investment portfolio is treated individually by
giving consideration to each purchase or sale for the client’s account. For these and other reasons,
performance of client investment portfolios within the same investment objectives, goals and/or risk
tolerance may differ, and clients should not expect that the composition or performance of their
investment portfolios would necessarily be consistent with similar clients of ours.
Private Funds
We will from time to time, based on the client’s risk tolerance, sophistication and financial
qualifications, recommend that a portion of the client’s assets be invested in certain private
investments. These include private equity, private debt and real estate funds, hedge funds, and other
types of private investment vehicles (collectively “Private Funds”).
We will assist clients in implementation of such recommendations to invest in Private Funds;
however, we do not exercise discretion with respect to these types of investments. We will continue
to render the advisory services to the client, relative to the ongoing monitoring and review of asset
performance and due diligence of the Private Fund. Clients are provided with private placement
memorandums and other offering and subscription documentation that detail the nature, risks and
associated fees of each Private Fund. It is important that the client read and review these documents
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with their legal and tax advisors, before investing, to fully understand the types of investments, risks
and conflicts pertaining to the Private Funds.
NHCO Lower Middle Market PE I, LP
NHCO serves as the Lead Investment Sub-Advisor of the NHCO Lower Middle Market PE I, LP (the
“Fund”), a private equity fund that primarily invests in underlying, externally managed private funds
(“Portfolio Funds”). Gridline Platform GP, LLC serves as the General Partner and its affiliate, Gridline
Advisors, is the Investment Manager of the Fund. NHCO has been delegated primary discretionary
authority over investment sourcing, due diligence, and investment recommendations for the Fund,
subject to limited veto rights of the Investment Manager and General Partner. From time to time, as
appropriate and in accordance with the established Investment Plan and risk tolerance of certain of
our clients, we recommend investments in the Fund.
Factors that we consider
Separate Account Managers
When appropriate and in accordance with the Investment Plan for a client, we may recommend the
use of one or more separate account managers, each a “Manager”. Having access to various Managers
offers a wide variety of manager styles and offers clients the opportunity to utilize more than one
Manager if necessary to meet the needs and investment objectives of the client. We will select the
in
Manager(s) we deem most appropriate for the client.
recommending/selecting Managers generally includes the client’s stated investment objective(s),
management style, performance, risk level, reputation, financial strength, reporting, pricing, and
research.
The Manager(s) will be granted discretionary trading authority to provide investment supervisory
services for the portfolio, but we normally retain the authority to terminate the Manager’s
relationship or to add new Managers without specific client consent. With respect to assets managed
by a Manager, our role will be to monitor the overall financial situation of the client, to monitor the
investment approach and performance of the Manager(s), conduct on-going due diligence, and to
assist the client in understanding the investments of the portfolio.
In instances where the services of one or more Managers are utilized, the fee assessed by the
Manager(s) will be separate and in addition to our fee and will be detailed in a Management
Agreement signed by the client.
Additionally, certain Managers
may impose more restrictive account requirements than NHCO, and
billing practices may vary. In such instances, we may be required to alter our corresponding account
requirements and/or billing practices to accommodate those of the Manager(s).
Retirement Plan Advisory Services
Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring
that prudent procedural steps are followed in making investment decisions. We will provide
Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The particular
services provided will be detailed in the consulting agreement. The appropriate Plan Fiduciary(ies)
designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i) make the
decision to retain our firm; (ii) agree to the scope of the services that we will provide; and (iii) make
the ultimate decision as to accepting any of the recommendations that we may provide. The Plan
Fiduciaries are free to seek independent advice about the appropriateness of any recommended
services for the Plan. Retirement Plan consulting services may be offered individually or as part of a
comprehensive suite of services.
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The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan
Fiduciaries may retain investment advisers for various types of services with respect to Plan assets.
For certain services, we will be considered a fiduciary under ERISA.
With respect to any account for which we meet the definition of a fiduciary under Department of
Labor rules, we acknowledge that both NHCO and its Related Persons are acting as fiduciaries.
Additional disclosure may be found elsewhere in this Brochure or in the written agreement between
us and Client.
Consulting
Fiduciary
Services
Investment Selection Services
•
We will provide Plan Fiduciaries with recommendations of investment options consistent
with ERISA section 404(c). Plan Fiduciaries retain responsibility for the final determination
of investment options and for compliance with ERISA section 404(c).
• Non-Discretionary Investment Advice
We provide Plan Fiduciaries and Plan Participants general, non-discretionary investment
advice regarding asset classes and investments.
Investment Monitoring
•
We will assist in monitoring the plan’s investment options by preparing periodic investment
reports that document investment performance, consistency of fund management and
conformation to the guidelines set forth in the investment policy statement and we will make
recommendations to maintain or remove and replace investment options. The details of this
aspect of service will be enumerated in the engagement agreement between the parties.
Non-Fiduciary Services
• Participant Education
We will provide education services to Plan Participants about general investment principles
and the investment alternatives available under the Plan. Education presentations will not
take into account the individual circumstances of each Plan Participant and individual
recommendations will not be provided unless a Plan Participant separately engages us for
such services. Plan Participants are responsible for implementing transactions in their own
accounts.
• Participant Enrollment
We will assist with group enrollment meetings designed to increase retirement Plan
participation among employees and investment and financial understanding by the
employees.
Retirement Plan Rollovers
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are also
fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the
Internal Revenue Code, as applicable, which are laws governing retirement accounts. We must act in
your best interest and not put our interest ahead of yours. If we recommend that you roll over or
transfer your retirement assets into an account to be managed by us, such a recommendation creates
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a conflict of interest if we will earn a new (or increase our current) advisory fee because of the
rollover/transfer. You are under no obligation to roll over retirement assets to an IRA managed by
Item 5 - Fees and Compensation
us or to engage us to monitor and/or manage the account while maintained at your employer.
Item 12 - Brokerage Practices
General Fee Information
Fees paid to us are exclusive of all custodial and transaction costs paid to the client’s custodian,
brokers or other third-party consultants. Please see
for additional
information. Fees paid to us are also separate and distinct from the fees and expenses charged by
mutual funds, private funds, ETFs (exchange traded funds) or other investment pools to their
shareholders (generally including a management fee and fund expenses, as described in each fund’s
prospectus or offering materials). The client should review all fees charged by funds, brokers, us and
others to fully understand the total amount of fees paid by the client for investment and financial-
related services.
Financial Planning Fees
When we provide financial planning services to clients, these services are generally part of our
portfolio management services. If a separate fee is to be charged for financial planning, it will be
negotiated at the time of the engagement for such services and will normally be in the form of a fixed
fee.
Portfolio Management Fees
The annual fee schedule, based on a percentage of assets under management, is as follows:
First $1,000,000
Next $2,000,000
Next $2,000,000
Next $5,000,000
Next $10,000,000
Amounts over $20,000,000
1.25%
1.00%
0.75%
0.50%
0.40%
0.30%
Although we have established the standard fee structure set forth above, we retain the discretion to
negotiate or waive fees on a client-by-client basis. We may also negotiate a fixed fee or negotiate a
minimum portfolio value and/or a minimum fee. In proposing the fee structure for your account(s),
we consider the nature of our proposed advisory relationship, which is determined by the assets to
be placed under our management, anticipated future additional assets, the complexity of financial
planning services to be provided, other accounts you may have with us, account type, portfolio style,
account composition, and reporting, among other factors. Your specific annual fee structure is
described in your Advisory Agreement (“Agreement”) with us. Also, pre-existing advisory clients are
subject to any minimum fee requirements and advisory fees in effect at the time the client entered
into the advisory relationship with us. Therefore, the applicable minimum fee requirements as well
as advisory fees paid will differ among clients, and other clients may pay less than you or have lower
minimums.
Asset-based portfolio management fees are generally payable quarterly, in arrears. The client’s total
asset value at the end of each month in the quarter are averaged to calculate the “average monthly
balance” for the quarter. The average monthly balance is applied to the annual fee schedule set out
in the client’s Agreement and then divided by four (4) to calculate the quarterly fee. Clients with a
fixed fee arrangement may be charged quarterly in advance or arrears. Our policy is to round fee
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values to the nearest whole dollar. Each client’s specific fee arrangement is detailed in the client’s
Agreement with us.
If management begins after the start of a quarter, fees will be prorated accordingly. With client
authorization and unless other arrangements are made, fees are normally debited directly from client
account(s).
Either we or the client may terminate the Agreement at any time, subject to any written notice
requirements in the Agreement. In the event of termination, any paid but unearned fees will be
promptly refunded to the client based on the number of days that the account was managed, and any
fees due us from the client will be invoiced or deducted from the client’s account prior to termination.
Private Fund Fees
When a client invests in a Private Fund, the fees and other expenses assessed by the Private Fund will
be separate from and in addition to our fee. Additionally, some of the Private Funds that we
recommend charge performance-based fees. Clients invested in private funds bear the following
expenses in addition to any management or similar fees paid in respect of the investment:
•
All costs, fees or expenses incurred in connection with:
−
−
−
−
−
−
−
due diligence reviews of the investment or manager;
negotiating, financing and documenting the investment or any sale or
recapitalization of the investment;
all brokers, accountants, tax advisors, administrators, lawyers, investment
bankers, consultants, auditors and other advisors;
all regulatory filings or any claim, action, suit, proceeding or litigation of any
kind or nature;
the administrator, the custodian, the depositary or any other fund service
providers;
underlying fees and expenses of pooled investment vehicles in which the
private funds invests, and
any line of credit or borrowing incurred by the fund.
The foregoing examples of expenses associated with private funds are not exhaustive. For details on
private fund expenses, please refer to the offering documents for the funds.
NHCO Lower Middle Market PE I, LP Fees
The Fund, and thus the Limited Partners, will pay (a) a 0.10% annual fee for the Investment Manager
providing operational, compliance, tax, reporting, and LP communication services to the Fund (the
“Management Fee”), and (b) a 1.00% annual sub-advisory fee (subject to periodic downward
adjustments) to NHCO for providing primary discretionary investment management services and
related advisory services (the “Sub-Advisory Fee”). Three employees of NHCO may also participate
in the Fund’s Carried Interest through an affiliated entity.
All investors will also bear their pro-rata portion of legal, accounting, and other non-investment
management expenses of the Fund, including a technology fee for access to the online investment
platform operated by Gridline, and the underlying fees and expenses of the Portfolio Funds in which
the Fund invests.
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We have an incentive to recommend that you invest in the Fund because we earn a Sub-Advisory Fee
and our affiliated entity earns Carried Interest, as such investments could increase the amount of
income that we derive from your assets. To help mitigate this conflict of interest, the Fund has agreed
to waive the Sub-Advisory Fee and Carried Interest (the “Fee Waiver”) for limited partners who are
NHCO advisory clients at the time they commit capital to the Fund (“Advisory Clients”). Instead,
Advisory Clients will pay the applicable portfolio management fees set forth in their Advisory
Agreement with NHCO based on the amount of their assets invested in the Fund. If an Advisory
Client’s engagement with NHCO is terminated, the Fee Waiver will no longer apply, and the Fund will
assess the limited partner the Sub-Advisory Fee and Carried Interest. For clarity, the Fee Waiver is
applicable when a Fund investor is an NHCO client at the time of their initial capital commitment to
the Fund. Limited partners who retain NHCO for advisory services subsequent to their investment in
the Fund will not be eligible for the Fee Waiver and will pay all fees and expenses associated with the
Fund (e.g., Management Fee, Sub-Advisory Fee, and Carried Interest) and NHCO’s portfolio
management fee.
NHCO employees, officers, members, and other affiliates who are investors in the Fund also receive
the Fee Waiver. The applicable fees and expenses of the Fund are outlined in its offering documents
and should be reviewed by clients prior to investing in such funds. In case of a conflict between the
summary above and the information provided in the Fund’s offering materials, the disclosures
contained in the offering materials supersede the information above.
Because the termination of an advisory relationship immediately causes a Limited Partner to become
subject to the Sub-Advisory Fee and the Carried Interest allocation, NHCO has a financial incentive to
end advisory relationships with Limited Partners to generate greater revenue for the firm and the
affiliated carried interest vehicle. NHCO has a fiduciary duty to exercise good faith and act solely in
the best interest of clients and maintains policies and procedures, including a Code of Ethics which
requires the interests of clients to be placed ahead of other interests to address this conflict of
interest.
Separate Account Manager Fees
Each Manager will assess its own fee, which will be charged according to the Manager’s established
fee schedule. This will be disclosed to the client prior to the time of the engagement.
Item 6 - Performance-Based Fees and Side-By-Side Management
For certain investors in the NHCO Lower Middle Market PE I, LP who are not eligible for the Fee
Waiver discussed in Item 5 above, an affiliated entity of NHCO earns Carried Interest consisting of a
percentage of the pooled investment vehicle’s distributions to investors. Carried Interest is a
performance fee, typically representing a portion of private investment fund's profits, which is paid
to the fund's general partners, managers and sub-advisors for their management and success in
generating returns for the investors (limited partners). The Carried Interest is 5% of the distributions
in excess of the return of capital and Preferred Return distributions to investors. The Preferred
Return which is distributed to investors prior to any Carried Interest is equal to an 8% cumulative
annual compounded return on each investor’s unreturned capital contributions. Underlying Portfolio
Funds may earn a Carried Interest even if the portfolio in the aggregate incurs a loss. A more detailed
description of the Carried Interest is included in the Fund’s offering memorandum.
Performance-based fee arrangements are only available if you meet the eligibility requirements of
Rule 205-3 under the Investment Advisers Act of 1940. The minimum requirements under the rule
state that you are generally not eligible unless you have at least $1,100,000 under management with
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us or have a net worth of at least $2,200,000. Performance-based fees are calculated and assessed in
arrears, and you should carefully review the fee calculations for accuracy.
Performance-based fee arrangements create certain conflicts of interest for us. For example, the
nature of a performance fee poses an opportunity for NHCO to earn more compensation than under
a stand-alone asset-based fee. Consequently, we could favor performance-based accounts over those
accounts where we receive only an asset-based fee. This could create an incentive for the portfolio
manager to allocate scarce investment opportunities to the Fund, which pays performance-based
fees. The nature of performance fees can also encourage us to take unnecessary risks with Fund
assets in order to earn or increase the amount of the fee or to dedicate more time to the Fund than
other accounts. The result of riskier investments can have a positive effect in that results could equal
higher returns when compared to an asset-based fee account. On the other hand, riskier investments
historically have a higher chance of losing value.
NHCO maintains and enforces written policies and procedures designed to ensure that allocation
decisions are made in a manner that we believe is consistent with our obligations and fiduciary duties
and that allocation decisions do not consistently advantage or disadvantage particular clients,
regardless of the fee arrangement. Fund portfolio managers regularly review investments to confirm
that they are consistent with the Fund's objectives.
Item 7 - Types of Clients
We serve individuals, pension and profit-sharing plans, trusts, foundations, private funds, and
estates. We may impose a minimum portfolio value eligible for conventional investment advisory
services and/or a minimum fee.
The minimum amounts to invest in private funds are disclosed in their respective offering
documents. Additionally, investors in private funds must meet specific suitability and investor
eligibility requirements in order to invest.
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
In accordance with the Investment Plan, we will primarily invest in ETFs, mutual funds, managed
accounts, some common stock, and bonds. Some clients have financial objectives and needs which
support consideration of Private Funds, which may include, without limitation, hedge funds,
investments in real estate, private equity and private debt.
ETFs and Mutual funds are generally evaluated and selected based on a variety of factors, including,
without limitation, past performance, fee structure, portfolio manager, fund sponsor, overall ratings
for safety and returns, and other factors.
Fixed income investments may be used as a strategic investment, as an instrument to fulfill liquidity
or income needs in a portfolio, or to add a component of capital preservation. We will generally
evaluate and select individual bonds or bond funds based on a number of factors including, without
limitation, rating, yield and duration.
Directly held equities may be used where tax efficiency, avoidance of third-party management fees,
and the potential for long-term dividend streams are desired by clients. We generally rely on third-
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party research reports from vendors like Refinitiv, Morningstar, and the Center for Financial
Research and Analysis (CFRA) to evaluate the appropriateness of directly held equities.
Private Funds are generally evaluated based on the previous performance and reputation of the
manager, fee structure, overall risk and returns, portfolio transparency, liquidity and other factors
specific to the type of investments involved.
Investment Strategies
Our strategic approach is to invest each portfolio in accordance with the Plan that has been developed
specifically for each client. This means that the following strategies may be used in varying
combinations over time for a given client, depending upon the client’s individual circumstances.
Long Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year.
Short Term Purchases – securities purchased with the expectation that they will be sold
within a relatively short period of time, generally less than one year, to take advantage of the
securities’ short-term price fluctuations.
Risk of Loss
While we seek to diversify clients’ investment portfolios across various asset classes consistent with
their Investment Plans in an effort to reduce risk of loss, all investment portfolios are subject to risks.
Accordingly, there can be no assurance that client investment portfolios will be able to fully meet
their investment objectives and goals, or that investments will not lose money.
Below is a description of several of the principal risks that client investment portfolios face.
Management Risks.
While we manage client investment portfolios based on our experience, research
and proprietary methods, the value of client investment portfolios will change daily based on the
performance of the underlying securities in which they are invested. Accordingly, client investment
portfolios are subject to the risk that we allocate client assets to individual securities and/or asset
classes that are adversely affected by unanticipated market movements, and the risk that our specific
investment choices could underperform their relevant indexes.
Selection and Monitoring of Managers and Funds
. There is a risk that NHCO, in its selection process,
will not identify appropriate external investment managers or Portfolio Funds for client portfolios,
existing weaknesses in an external investment manager’s compliance or operational controls or
existing material regulatory, financial, or other operational issues. Further, there is a risk that an
external investment manager or Portfolio Fund does not meet NHCO’s expectations over time,
develops significant weaknesses in its compliance or operational controls that could materially
adversely affect a client’s investment or could develop material regulatory, financial, or other
operational issues. We may rely upon representations made by external investment managers,
accountants, attorneys, prime brokers, and/or other investment professionals. If any such
representations are misleading, incomplete, or false, this may result in the selection of an external
investment manager that might have otherwise been eliminated from consideration had fully
accurate and complete information been made available to us.
Risks of Investments in Mutual Funds, ETFs and Other Investment Pools.
As described above, we will
usually invest client portfolios in mutual funds, ETFs and other investment pools (“pooled investment
funds”). Investments in pooled investment funds are generally less risky than investing in individual
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securities because of their diversified portfolios; however, these investments are still subject to risks
associated with the markets in which they invest. In addition, pooled investment funds’ success will
be related to the skills of their particular managers and their performance in managing their funds.
Pooled investment funds are also subject to risks due to regulatory restrictions applicable to
registered investment companies under the Investment Company Act of 1940.
Equity Market Risks.
We may invest portions of client assets directly into equity investments,
primarily stocks, or into pooled investment funds that invest in the stock market. As noted above,
while pooled investments have diversified portfolios that may make them less risky than investments
in individual securities, funds that invest in stocks and other equity securities are nevertheless
subject to the risks of the stock market. These risks include, without limitation, the risks that stock
values will decline due to daily fluctuations in the markets, and that stock values will decline over
longer periods (e.g., bear markets) due to general market declines in the stock prices for all
companies, regardless of any individual security’s prospects.
Fixed Income Risks.
We may invest portions of client assets directly into fixed income instruments,
such as bonds and notes, or may invest in pooled investment funds that invest in bonds and notes.
While investing in fixed income instruments, either directly or through pooled investment funds, is
generally less volatile than investing in stock (equity) markets, fixed income investments
nevertheless are subject to risks. These risks include, without limitation, interest rate risks (risks
that changes in interest rates will devalue the investments), credit risks (risks of default by
borrowers), or maturity risk (risks that bonds or notes will change value from the time of issuance
to maturity).
Foreign Securities Risks.
We may invest portions of client assets directly into foreign securities or
into pooled investment funds that invest internationally. While foreign investments are important
to the diversification of client investment portfolios, they carry risks that may be different from U.S.
investments. For example, foreign investments may not be subject to uniform audit, financial
reporting or disclosure standards, practices or requirements comparable to those found in the U.S.
Foreign investments are also subject to foreign withholding taxes and the risk of adverse changes in
investment or exchange control regulations. Finally, foreign investments may involve currency risk,
which is the risk that the value of the foreign security will decrease due to changes in the relative
value of the U.S. dollar and the security’s underlying foreign currency.
Risks Related to Private Funds
. From time to time and as appropriate, we may invest a portion of a
client’s portfolio in Private Funds. The value of client portfolios will be based in part on the value of
Private Funds in which they are invested, the success of each of which will depend heavily upon the
efforts of their respective Managers. When the investment objectives and strategies of a Manager are
out of favor in the market or a Manager makes unsuccessful investment decisions, the Private Fund
may lose money. A client account may lose a substantial percentage of its value if the investment
objectives and strategies of many or most of the Private Funds in which it is invested are out of favor
at the same time, or many or most of the Managers make unsuccessful investment decisions at the
same time. Private Funds are generally subject to various risk factors and liquidity constraints, a
complete discussion of which is set forth in each fund’s offering documents, which will be provided
to clients for review and consideration prior to investing. Investing in Private Funds is intended only
for experienced and sophisticated investors who are willing to bear the high economic risks of the
investment. Clients should carefully review and consider potential risks before investing in private
funds. Certain of these risks may include loss of all or a substantial portion of the investment due to
leveraging, short-selling, or other speculative practices, lack of liquidity because of redemption terms
and conditions and that there may not and will not be a secondary market for the fund, volatility of
Page 12
returns, restrictions on transferring interests in the fund, a potential lack of diversification, higher
fees than mutual funds, and lack of information regarding valuations and pricing.
Fund of Funds.
Unregistered investment funds managed or sub-advised by NHCO to provide exposure
to alternative investments are typically formed for the purpose of investing in underlying, externally
managed funds. Investors in NHCO managed funds will not be limited partners of any underlying
funds, will have no direct interest in any underlying funds, will have no voting rights in any
underlying funds, will not be party to any underlying fund’s governing documents and may not bring
an action for breach of any such governing documents. Returns, if any, to investors in NHCO funds
may be lower than returns, if any, to direct investors in the underlying funds as a result of the fees
and expenses charged by the NHCO managed funds. In addition, underlying funds in which NHCO
funds invest may take direct investors. Therefore an investment in a fund offered by NHCO may not
be necessary to participate in one or more underlying funds.
Real Estate Risk
. We may gain exposure to the real estate sector by investing in real estate or funds
that invest in real estate. These investments are subject to risks including loss to casualty or
condemnation, increases in property taxes and operating expenses, zoning law amendments,
changes in interest rates, overbuilding and increased competition, variations in market value, and
possible environmental liabilities.
Valuation Risk
. There is uncertainty as to the valuation of illiquid and other difficult-to-value assets
and investments in client portfolios, including private equity and alternative investments,
promissory notes and other debt instruments and real assets. NHCO has adopted valuation processes
designed to provide a methodology for valuing such assets and investments. Given the inherent
subjectivity of fair value processes, the valuations of illiquid and difficult-to-value assets and
investments may not reflect the values that could be realized by a client. In addition, NHCO may not
have access to current information or all material information relevant to a valuation analysis and it
may not be possible to consistently obtain up-to-date valuations. Generally, NHCO relies on valuation
statements from external fund managers and other third parties. NHCO does not have the ability to
assess the accuracy of such valuations. As a result, valuations may be inaccurate or not reflective of
current valuations resulting in fee calculations that may be higher or lower than they would be if
calculated on current, accurate valuations. In certain circumstances, valuation techniques may need
to be modified in order to capture what NHCO believes is current fair value. Finally, performance
calculations for clients who hold alternative and difficult-to-value assets and investments will be
inaccurate to the extent they rely on valuations that are not current or accurate.
Margin Risk.
We do not use margin as an investment strategy. However, you may elect to borrow
funds against your investment portfolio. For accounts with a margin balance, you are assessed the
management fee based on the gross value of the assets in your account. In other words, your account
value on which the fee is calculated is not reduced by the margin balance. This could create a conflict
of interest in which we may have an incentive to encourage the use of margin as this could result in
a higher market value and therefore an increased management fee. When securities are purchased,
they may be paid for in full or the client may borrow part of the purchase price from the account
custodian. If a client borrows part of the purchase price, the client is engaging in margin transactions
and there is risk involved with this. The securities held in a margin account are collateral for the
custodian that loaned the client money. If those securities decline in value, then the value of the
collateral supporting the client’s loan also declines. As a result, the brokerage firm is required to take
action in order to maintain the necessary level of equity in the client’s account. The brokerage firm
may issue a margin call and/or sell other assets in the client’s account to accomplish this. It is
Page 13
important that clients fully understand the risks involved in trading securities on margin, including
but not limited to:
•
•
•
•
•
•
Item 9 - Disciplinary Information
It is possible to lose more funds than is deposited into a margin account;
The account custodian can force the sale of assets in the account;
The account custodian can sell assets in the account without contacting the client first;
The account holder is not entitled to choose which assets in a margin account may be sold
to meet a margin call;
The account custodian can increase its “house” maintenance margin requirements at any
time without advance written notice; and
The accountholder is not entitled to an extension of time on a margin call.
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to a client’s evaluation of us or the integrity of our
Item 10 - Other Financial Industry Activities and Affiliations
management. We have no disciplinary events to report.
Neither NHCO nor its Management Persons have any other financial industry activities or affiliations
to report.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics and Personal Trading
We have adopted a Code of Ethics (“the Code”), the full text of which is available to you upon request.
Our Code has several goals. First, the Code is designed to assist us in complying with applicable laws
and regulations governing its investment advisory business. Under the Investment Advisers Act of
1940, we owe fiduciary duties to its clients. Pursuant to these fiduciary duties, the Code requires
persons associated with us (managers, officers and employees) to act with honesty, good faith and
fair dealing in working with clients. In addition, the Code prohibits such associated persons from
trading or otherwise acting on insider information.
Next, the Code sets forth guidelines for professional standards for NHCO’s associated persons. Under
the Code’s Professional Standards, NHCO expects its associated persons to put the interests of its
clients first, ahead of personal interests. In this regard, NHCO associated persons are not to take
inappropriate advantage of their positions in relation to our clients.
Third, the Code sets forth policies and procedures to monitor and review the personal trading
activities of associated persons. From time to time, NHCO’s associated persons may invest in the
same securities recommended to clients. In the Code, we have adopted procedures designed to
reduce or eliminate conflicts of interest that this could potentially cause. The Code’s personal trading
policies include procedures for limitations on personal securities transactions of associated persons,
reporting and review of such trading and pre-clearance of certain types of personal trading activities.
These policies are designed to discourage and prohibit personal trading that would disadvantage
clients. The Code also provides for disciplinary action as appropriate for violations.
Participation or Interest in Client Transactions
If appropriate, we recommend that clients invest in the NHCO Lower Middle Market PE I, LP, for
which we serve as the sub-advisor. As described in more detail above, the Fund pays NHCO an asset-
Page 14
based Sub-Advisory Fee and Carried Interest. In order to ensure that NHCO’s Advisory Clients do not
pay NHCO or its affiliates multiple levels of fees, the Fund does not charge a Sub-Advisory Fee and
Carried Interest payable by the Fund to NHCO or its affiliates for any NHCO Advisory Client that pays
an asset-based portfolio management fee to NHCO, unless the Advisory Client retains NHCO after the
Advisory Client’s initial capital commitment to the Fund.
Because client accounts are primarily invested in open end mutual funds, pooled investment vehicles
and independently managed accounts there is little opportunity for a conflict of interest between
personal trades by NHCO associated persons and trades in client accounts, even when such accounts
invest in the same securities. However, in the event of other identified potential trading conflicts of
interest, our goal is to place client interests first.
Consistent with the foregoing, we maintain policies regarding participation in initial public offerings
(“IPOs”) and private placements to comply with applicable laws and avoid conflicts with client
transactions. If an NHCO associated person wishes to participate in an IPO or invest in a private
placement, he or she must submit a pre-clearance request and obtain the approval of the Chief
Compliance Officer.
Finally, if associated persons trade with client accounts (i.e., in a bundled or aggregated trade), and
the trade is not filled in its entirety, the associated person’s shares will be removed from the block,
and the balance of shares will be allocated among client accounts in accordance with our written
Item 12 - Brokerage Practices
policy.
The custodians and brokers we use
Item 15 – Custody
We do not maintain custody of your assets that we manage or on which we advise, although we may
be deemed to have custody of your assets if you give us authority to withdraw assets from your
account (see
, below).
Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or
bank. We recommend that most of our clients use Charles Schwab & Co., Inc. (“Schwab”), as the
qualified custodian. In certain limited instances, we may recommend the custodial services of
Fidelity Institutional Wealth Services (“Fidelity”), a division of Fidelity Brokerage Services LLC, for
ultra-high-net-worth clients who would benefit from Fidelity’s suite of family office services. Schwab
and Fidelity (together, the “Custodians”) are registered broker-dealers, members SIPC. We are
independently owned and operated and are not affiliated with the Custodians.
The account custodian will hold your assets in a brokerage account and buy and sell securities when
we (or you) instruct them to. While we recommend that you use Schwab (or Fidelity in limited
instances) as custodian/broker, you will decide whether to do so and will open your account with
the custodian by entering into an account agreement directly with them. We do not open the account
for you, although we may assist you in doing so. Even though your account is maintained at one of
our recommended custodians, we can still use other brokers to execute trades for your account as
described below (see “Your brokerage and custody costs”)
How we select brokers/custodians
We seek to recommend a custodian/broker that will hold your assets and execute transactions on
terms that are overall most advantageous when compared with other available providers and their
services. We consider a wide range of factors, including, but not limited to:
Page 15
•
•
•
•
•
•
•
•
•
•
•
Combination of transaction execution services and asset custody services (generally without
a separate fee for custody)
Capability to execute, clear, and settle trades (buy and sell securities for your account)
Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill
payment, etc.)
Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded
funds (ETFs), etc.)
Availability of investment research and tools that assist us in making investment decisions
Quality of services
Competitiveness of the price of those services (commission rates, margin interest rates, other
fees, etc.) and willingness to negotiate the prices
Reputation, financial strength, security and stability
Prior service to us and our clients
Availability of other products and services that benefit us, as discussed below (see “Products
and services available to us from the Custodians”)
Your brokerage and custody costs
The Custodians generally do not charge you separately for custody services but are compensated by
charging you commissions or other fees on trades that they execute or that settle into your account.
Certain trades may not incur commissions or transaction fees. The Custodians are also compensated
by earning interest on the uninvested cash in your account. In addition to commissions, you may be
charged a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have
executed by a different broker-dealer but where the securities bought or the funds from the securities
sold are deposited (settled) into your account. These fees are in addition to the commissions or other
compensation you pay the executing broker/dealer. Because of this, in order to minimize your
trading costs, we have your account custodian execute most trades for your account. We have
determined that having you account custodian execute most trades is consistent with our duty to
seek “best execution” of your trades. Best execution means the most favorable terms for a transaction
based on all relevant factors, including those listed above (see “How we select brokers/custodians”).
Products and services available to us from the Custodians
The Custodians provide our clients and us with access to their institutional brokerage services
(trading, custody, reporting and related services), many of which are not typically available to their
retail customers. They also make available various support services. Some of those services help us
manage or administer our clients’ accounts, while others help us manage and grow our business.
These support services are generally available on an unsolicited basis (we don’t have to request
them) and at no charge to us. Following is a more detailed description of the support services offered
by the Custodians:
Services That Benefit You.
The Custodians’ brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. They make investment products
available to us that include some to which we might not otherwise have access or that would require
a significantly higher minimum initial investment by our clients. Such services generally benefit you
and your account.
Page 16
Services that may not directly benefit you.
The Custodians also make available to us other products and services that benefit us but may not
directly benefit you or your account. These products and services assist us in managing and
administering our clients’ accounts. They include investment research, both their own and that of
third parties. We may use this research to service all or a substantial number of our clients’ accounts,
including accounts not maintained at the custodian from which we obtained the research. In addition
to investment research, the Custodians also make available software and other technology that:
•
•
•
•
•
provide access to client account data (such as duplicate trade confirmations and account
statements)
facilitate trade execution and allocate aggregated trade orders for multiple client
accounts
provide pricing and other market data
facilitate payment of our fees from our clients’ accounts
assist with back-office functions, recordkeeping, and client reporting
Services that generally benefit only us.
The Custodians also offer other services intended to help us manage and further develop our business
enterprise. These services include:
•
•
•
•
•
Educational conferences and events
Consulting on technology, compliance, legal, and business needs
Publications and conferences on practice management and business succession
Access to employee benefits providers, human capital consultants, and insurance
providers
Marketing consulting and support
The Custodians may provide some of these services themselves. In other cases, they will arrange for
third-party vendors to provide the services to us. They may also discount or waive their fees for some
of these services or pay all or a part of a third party’s fees. We also may be provided with other
benefits such as occasional business entertainment of our personnel.
Our interest in the Custodians’ services
The availability of these services from the Custodians benefits us because we do not have to produce
or purchase them. These services are not contingent upon us committing any specific amount of
business to the Custodians in trading commissions or assets in custody. However, the benefits that
we and our clients receive create an incentive to recommend that you maintain your account with
the Custodians, based on our interest in receiving their services that benefit our business and their
payment for services for which we would otherwise have to pay rather than based on your interest
in receiving the best value in custody services and the most favorable execution of your transactions.
This is a conflict of interest.
We believe, however, that our recommendation of the Custodians is in the best interests of our
clients. Our selection is primarily supported by the full scope, quality, and price of their services (see
“How we select brokers/ custodians”) and not the services that benefit only us.
Directed Brokerage
Clients may direct us to use a particular broker for custodial or transaction services on behalf of the
client’s portfolio. In directed brokerage arrangements, the client is responsible for negotiating the
commission rates and other fees to be paid to the broker. Accordingly, a client who directs brokerage
should consider whether such designation may result in certain costs or disadvantages to the client,
Page 17
either because the client may pay higher commissions or obtain less favorable execution, or the
designation limits the investment options available to the client.
The arrangements that we have with the Custodians is designed to maximize efficiency and to be cost
effective. By directing brokerage arrangements, the client acknowledges that these economies of
scale and levels of efficiency are generally compromised when alternative brokers are used. While
every effort is made to treat clients fairly over time, the fact that a client chooses to use the brokerage
and/or custodial services of these alternative service providers can in fact result in a certain degree
of delay in executing trades for their account(s) and otherwise adversely affect management of their
account(s).
By directing us to use a specific broker or dealer, clients who are subject to ERISA confirm and agree
with us that they have the authority to make the direction, that there are no provisions in any client
or plan document which are inconsistent with the direction, that the brokerage and other goods and
services provided by the broker or dealer through the brokerage transactions are provided solely to
and for the benefit of the client’s plan, plan participants and their beneficiaries, that the amount paid
for the brokerage and other services have been determined by the client and the plan to be
reasonable, that any expenses paid by the broker on behalf of the plan are expenses that the plan
would otherwise be obligated to pay, and that the specific broker or dealer is not a party in interest
of the client or the plan as defined under applicable ERISA regulations.
Aggregated Trade Policy
We typically direct trading in individual client accounts as and when trades are appropriate based
on the client’s Investment Plan, without regard to activity in other client accounts. However, from
time to time, we may aggregate trades together for multiple client accounts, most often when these
accounts are being directed to sell the same securities. If such an aggregated trade is not completely
filled, we will allocate shares received (in an aggregated purchase) or sold (in an aggregated sale)
across participating accounts on a pro rata or other fair basis; provided, however, that any
participating accounts that are owned by us or our officers, directors, or employees will be excluded
Item 13 - Review of Accounts
first.
Managed portfolios are generally reviewed quarterly but may be reviewed more often if requested
by the client, upon receipt of information material to the management of the portfolio, or at any time
such review is deemed necessary or advisable by us. These factors generally include but are not
limited to the following: change in general client circumstances (marriage, divorce, retirement); or
economic, political or market conditions. Nicholas J. Hoffman, a designated Principal, or a Senior
Investment Advisor of the firm, review all accounts.
Account custodians are responsible for providing monthly or quarterly account statements which
reflect the positions (and current pricing) in each account as well as transactions in each account,
including fees paid from an account. Account custodians also provide prompt confirmation of all
trading activity, and year-end tax statements, such as 1099 forms. In addition, we provide at least an
annual report for each managed portfolio. This written report normally includes a summary of
portfolio holdings and performance results. Additional reports are available at the request of the
client.
Page 18
Item 14 - Client Referrals and Other Compensation
Item 12 - Brokerage Practices.
As noted above, we receive an economic benefit from the Custodians in the form of support products
and services they make available to us and other independent investment advisors whose clients’
accounts they maintain. These products and services, how they benefit our firm, and the related
conflicts of interest are described in
The availability of the products
and services the Custodians provide to us are based solely on our participation in their programs and
not on the provision of any particular investment advice.
Item 15 - Custody
Schwab is the custodian of the large majority of our client accounts. From time to time however,
clients may select an alternate broker to hold accounts in custody. In any case, it is the custodian’s
responsibility to provide clients with confirmations of trading activity, tax forms and at least
quarterly account statements. Clients are advised to review this information carefully, and to notify
us of any questions or concerns. Clients are also asked to promptly notify us if the custodian fails to
provide statements on each account held.
From time to time and in accordance with our Agreement with clients, we will provide additional
reports. The account balances reflected on these reports should be compared to the balances shown
on the brokerage statements to ensure accuracy. At times, there may be small differences due to the
timing of dividend reporting and pending trades or similar issues.
Item 16 - Investment Discretion
Item 4 - Advisory Business
discretionary accounts
, we will accept clients on either a discretionary or non-
As described in
, a Limited Power of Attorney (“LPOA”) is executed by
discretionary basis. For
the client, giving us the authority to carry out various activities in the account, generally including
the following: trade execution; the ability to request checks on behalf of the client; and the
withdrawal of advisory fees directly from the account. We then direct investment of the client’s
portfolio using its discretionary authority. The client may limit the terms of the LPOA to the extent
consistent with the client’s Agreement with us and the requirements of the client’s custodian.
non-discretionary
For
accounts, the client also generally executes an LPOA, which allows us to carry
out trade recommendations and approved actions in the portfolio. However, in accordance with the
Agreement between us and the client, we do not implement trading recommendations or other
actions in the account unless and until the client has approved the recommendation or action. As
with discretionary accounts, clients may limit the terms of the LPOA, subject to our Agreement with
Item 17 - Voting Client Securities
the client and the requirements of the client’s custodian.
As a policy and in accordance with our Agreement, we do not vote proxies related to securities held
in client accounts. The custodian of the account will normally provide proxy materials directly to the
client. Clients may contact us with questions relating to proxy matters; however, we do not generally
perform detailed research regarding proxy voting options.
Item 18 - Financial Information
We do not require nor solicit prepayment of more than $1,200 in fees per client, six months or more
in advance, and therefore have no disclosure required for this item.
Page 19
Exhibit A
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Nicholas J. Hoffman
CRD# 1513288
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
August 19, 2025
This Brochure Supplement provides information about Nick Hoffman, and supplements the Nicholas
Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Nick is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Nicholas J. Hoffman (year of birth 1957) founded NHCO in 2007 and has overall responsibility for its
management and the investment strategies for all clients. From 2002 until 2007, Nick was a partner
with Diversified Trust, a southeastern based Private Trust Company. Prior to that, he was a partner
with Balentine & Company (1992 - 2001) a local Investment Advisory firm now a part of Wilmington
Trust, where Nick designed and directed the firm’s integrated approach to strategic tax and financial
planning.
Money and Finance
th
Grade at Pace Academy on
Nick served for over sixteen years on the Board of Goodwill Industries (Atlanta), including serving as
Chairman. He also serves on the Board and is a past Chairman of the Society of International Business
fellows (“SIBF”). As the founder of “The Responsibility of Wealth Forum”, he has been featured on
National Public Radio (“NPR”) as well as in several national publications. He has also taught a course
and conducts an annual summer program
to the 12
on “Money & Responsibility” at Cambridge University.
Exhibit A-1
Nick was born and educated in England, where he received an honors degree in Law from the
University of Exeter. He began his career as a Chartered Accountant with KPMG in London and
Item 3 - Disciplinary Information
Germany. He is a Fellow of the Institute of Chartered Accountants.
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Nick has no such disciplinary
information to report.
Item 4 - Other Business Activities
Nick is not engaged in any other business activities.
Item 5 - Additional Compensation
Item 6 - Supervision
Nick has no other income or compensation to disclose.
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Nick and
may be reached at (404) 815-5050.
Exhibit A-2
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Gary B. Martin, CFA
CRD# 1686747
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
August 19, 2025
This Brochure Supplement provides information about Gary Martin, and supplements the Nicholas
Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Gary is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Gary B. Martin (year of birth 1961) is a Principal of NHCO with responsibilities that include client
account management and general firm directives. Gary is also a member of NHCO’s Investment
Management Committee, which oversees the investment process. He has over forty years of financial
services experience. For more than thirty years, Gary has worked extensively with individuals and
their families providing comprehensive wealth management. Gary’s expertise includes investment
management and allocation, manager research and all aspects of the financial planning process.
Prior to joining NHCO in 2009, Gary was with Wilmington Trust Company as the senior team leader
responsible for managing the largest private wealth group within the Atlanta office for six years.
Prior to that, he was a senior partner with Balentine & Company an Atlanta based investment
advisory firm that was acquired by Wilmington Trust in 2002. Gary began his career on Wall Street
spending the first seven years with Bankers Trust Company and then UBS Securities where he
worked in various institutional sales and trading functions.
Exhibit A-3
®
designation* in 1997.
Gary was born in Chicago, received his undergraduate degree from Harvard University, and his
graduate degree in business administration from Emory University. He received his Chartered
Financial Analyst
Gary and his wife live in the Virginia Highland neighborhood of Atlanta and have five adult children.
Gary is an avid cyclist, ice hockey player and fitness enthusiast.
®
®
(“CFA
”) designation is a professional designation given by the
* The Chartered Financial Analyst
CFA Institute that measures the competence and integrity of financial analysts. The CFA Program is
a graduate-level self-study program that combines a broad-based curriculum of investment
principles with professional conduct requirements. Candidates are required to pass three levels of
examinations covering areas such as accounting, economics, ethics, money management and security
analysis. Before a candidate is eligible to become a CFA charterholder, he/she must meet minimum
experience requirements in the area of investment/financial practice. To enroll in the program, a
Item 3 - Disciplinary Information
candidate must hold a bachelor’s degree.
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Gary has no such disciplinary
Item 4 - Other Business Activities
information to report.
Item 5 - Additional Compensation
Gary is not engaged in any other business activities.
Gary has no other income or compensation to disclose.
Item 6 - Supervision
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Gary and
may be reached at (404) 815-5050.
Exhibit A-4
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
A. Carl Gambrell
CRD# 1270376
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
August 19, 2025
This Brochure Supplement provides information about Carl Gambrell, and supplements the Nicholas
Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Carl is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
A. Carl Gambrell (year of birth 1955) is a Principal of NHCO with responsibilities that include client
account management and general firm directives. Carl is also a member of NHCO’s Investment
Management Committee, which oversees the investment process. He has extensive experience as an
investment professional with over forty-five years as a portfolio manager and an institutional fixed
income specialist. Prior to joining NHCO in 2009, Carl was a director with Merrill Lynch (eleven
years) and Credit Suisse First Boston (fourteen years). His depth of product expertise covers all fixed
income securities.
Over the course of his career, Carl has had client relationship responsibilities for some of the largest
and most sophisticated institutional accounts in the country including international money
managers, life insurance companies, public pension funds, hedge funds and major US commercial
banks. During the first seven years of his career, Carl was a Senior Vice President and head of the
investment department at two financial institutions in the Southeast with responsibilities for security
selection, market timing, and asset liability management.
Exhibit A-5
Carl graduated from Mississippi State University with a degree in Finance. He and his wife have two
daughters. Carl is a member of the First Presbyterian Church of Atlanta. He is passionate about
Item 3 - Disciplinary Information
college football and loves working on renovation projects around his home.
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Carl has no such disciplinary
information to report.
Item 4 - Other Business Activities
Carl is not engaged in any other business activities.
Item 5 - Additional Compensation
Item 6 - Supervision
Carl has no other income or compensation to disclose.
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Carl and
may be reached at (404) 815-5050.
Exhibit A-6
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Eleanor D. Quarles
CRD# 1422288
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
August 19, 2025
This Brochure Supplement provides information about Eleanor Quarles, and supplements the
Nicholas Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that
Brochure. Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have
any questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Eleanor is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Eleanor D. Quarles (year of birth 1960) is the Director of Client Services for NHCO, where she is
responsible for client account administration and operations. Prior to joining NHCO in 2007, Eleanor
worked as a Client Service Officer for Wilmington Trust Wealth Advisory Services, servicing high net
worth families, individuals and foundations for seventeen years. She was a member of Wilmington
Trust’s Diversity Council to the National Offices.
Eleanor began her career at Merrill Lynch Pierce Fenner and Smith in Princeton, New Jersey. She is
a graduate of Douglas College, Rutgers University.
Eleanor is a founding member of Transformational Ministries International, formerly known as First
Congregation Ministries of Stone Mountain, Georgia, where she participates in various community
outreach initiatives from finances to emotional health. She was a founding member of New Creation
Christian Fellowship where she served as the Director of the Children’s Church and facilitated
Restored, a divorce support outreach ministry. She was a founding member of the women’s
Exhibit A-7
investment club, Increasing Wealth Amongst My Sisters, better known as IWAMS and served as
president for one term. Eleanor currently Serves on the Advisory Committee of Transformational
Ministries Global Network, a 501(c)(3) initiative that promotes financial literacy through its program
called In The Black On The Plus Side. She and her husband have 3 sons.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Eleanor has no such disciplinary
Item 4 - Other Business Activities
information to report.
Item 5 - Additional Compensation
Eleanor is not engaged in any other business activities.
Eleanor has no other income or compensation to disclose.
Item 6 - Supervision
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Eleanor
and may be reached at (404) 815-5050.
Exhibit A-8
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Cameron R. Simonds
CRD# 5389633
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
August 19, 2025
This Brochure Supplement provides information about Cam Simonds, and supplements the Nicholas
Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Cam is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Cameron R. Simonds (year of birth 1984) is Senior Investment Advisor for NHCO with
responsibilities including client account management and participation in developing the firm’s
investment platform, primarily in the private investing arena. Cam works with clients on investment
strategy and allocation, strategic planning, and cash flow management.
Prior to joining NHCO in 2011, Cam was with Executive Advisor Group as an Associate where he
gained experience in portfolio management operations and comprehensive financial planning.
Cam grew up in Atlanta, attended Pace Academy and is a graduate of Presbyterian College with a
bachelor’s degree in Business Administration.
Exhibit A-9
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Cam has no such disciplinary
information to report.
Item 4 - Other Business Activities
Cam is not engaged in any other business activities.
Item 5 - Additional Compensation
Item 6 - Supervision
Cam has no other income or compensation to disclose.
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Cam and
may be reached at (404) 815-5050
Exhibit A-10
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Richard Rushton
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
August 19, 2025
This Brochure Supplement provides information about Richard Rushton, and supplements the
Nicholas Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that
Brochure. Please contact NHCO at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you
have any questions about the contents of this Supplement.
Item 2 - Educational Background and Business Experience
Richard Rushton (year of birth 1958) serves as Chief Compliance Officer and Chief Operating Officer
and advises NHCO on all operational and compliance matters. Richard is also a member of NHCO’s
Investment Management Committee, which oversees the investment process. Richard initially
assisted with the formation of NHCO and continued to serve in a dedicated consulting role until
formally joining the firm in 2015. He has over twenty-six years of experience in business
management, consulting, and economic analysis.
After working initially as an economist and policy advisor in London, England, Richard spent ten
years consulting for, and then managing, fast growing retail banking operations including mortgages,
savings and investment services. In the U.S., he jointly led the growth of a Federal services provider
from annual revenues of $15 million to $350 million over a ten-year period. In 2001, the Company
was sold to a publicly quoted UK company. Richard subsequently served as CEO of the U.S. Company,
and as a member of the Executive Board of the British parent company.
Richard was born and educated in England. He received his undergraduate degree from the
University of Reading, and his graduate degree in Economics from the University of Oxford. Richard
is a past Chair of Soccer in the Streets, and Goodwill Industries of North Georgia. He and his wife have
three sons and a daughter.
Exhibit A-11
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Richard has no such disciplinary
information to report.
Item 4 - Other Business Activities
Richard is not engaged in any other business activities.
Item 5 - Additional Compensation
Item 6 - Supervision
Richard has no other income or compensation to disclose.
As the firm’s Chief Operating Officer and Chief Compliance Officer, Richard is responsible for
oversight of the firm's advisory services activities and its associated staff. As sole owner of the firm,
Nicholas Hoffman is responsible for oversight of Mr. Rushton. Please address questions relative to
the firm, staff, its services, or this ADV Part 2 or any Advisory Supplemental Brochure to the attention
of Richard or Nick at (404) 815-5050. Additional information about our firm, other advisory firms,
or an associated representative is available at www.adviserinfo.sec.gov.
Exhibit A-12
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Michael W. Masters, MBA
CRD# 5495395
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
August 19, 2025
This Brochure Supplement provides information about Mike Masters, and supplements the Nicholas
Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Mike is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Michael W. Masters (year of birth 1964) is a Senior Investment Advisor for NHCO with
responsibilities including client account management and participation in developing the firm’s
investment platform, primarily in public investing and hedge funds. Mike works with clients on
investment strategy, asset allocation and security selection, performance monitoring, and cash flow
management.
Mike has over 25 years of financial market experience. Prior to joining Nicholas Hoffman & Company
in 2014, Mike worked as Vice President and Portfolio Manager at Sterling Investment Management,
Inc. where he was responsible for managing the investment portfolios of several affluent families.
Prior to joining Sterling, Mike worked as Portfolio Manager at Daniel Financial Group where he was
responsible for more than $50 million in assets under management. Previously he has worked in the
equity research department of a mutual fund company with more than $500 million in assets under
management. He has also performed buy-side equity research for a private investment partnership
where he supported a team that managed a concentrated stock portfolio.
Exhibit A-13
Mike holds a BA in Philosophy from Emory University where he graduated with honors. He holds an
MBA in Finance and Real Estate from Georgia State University. Mike is a member of the CFA
Institute and the Atlanta CFA Society.
Mike and his wife Kathy are avid cyclists and fitness enthusiasts.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Mike has no such disciplinary
Item 4 - Other Business Activities
information to report.
Item 5 - Additional Compensation
Mike is not engaged in any other business activities.
Mike has no other income or compensation to disclose.
Item 6 - Supervision
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Mike and
may be reached at (404) 815-5050.
Exhibit A-14
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Lloyd B. Flood, CFA
CRD# 6869285
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
August 19, 2025
This Brochure Supplement provides information about Lloyd Flood, and supplements the Nicholas
Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Lloyd is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Lloyd B. Flood (year of birth 1962) joined NHCO in 2017 and serves as a Senior Investment Advisor.
Lloyd has thirty years of experience working as a portfolio manager, trader, and financial analyst. He
has deep knowledge of financial markets, and the importance of asset allocation and due diligence.
Lloyd has been in Atlanta for the entirety of his professional life, spending ten years at Bank
South/Bank of America (1985-1995), and twenty years at ING/Voya (1996-2016). During that time,
he worked in both the public and private asset classes with a primary focus on fixed income. He
managed assets for company accounts and trusts, partnering with clients on the customized mandate
and portfolio construction process. Lloyd has a real insider’s perspective on how Wall Street and the
markets function.
Lloyd was born and raised in the south. He earned a bachelor’s degree in business administration in
finance from Auburn University (1984), a master’s degree in business administration from Mercer
University (1990) and became a CFA charterholder (1997). He is a member of the CFA Institute. Lloyd
also completed the Certified Financial Planner™ practitioner program (2019); however, he no longer
Exhibit A-15
maintains this certification. Lloyd was selected for the ING Business Program in the Netherlands
(2000).
Lloyd’s volunteer activities have been primarily related to his children’s schools starting at the Lovett
School and continuing most recently by serving on the parents’ council at Washington College in
Chestertown, MD. He spends his free time enjoying being with his family in Atlanta, with an
occasional trip to the NC mountains.
®
®
(“CFA
”) designation is a professional designation given by the
* The Chartered Financial Analyst
CFA Institute that measures the competence and integrity of financial analysts. The CFA Program is
a graduate-level self-study program that combines a broad-based curriculum of investment
principles with professional conduct requirements. Candidates are required to pass three levels of
examinations covering areas such as accounting, economics, ethics, money management and security
analysis. Before a candidate is eligible to become a CFA charterholder, he/she must meet minimum
experience requirements in the area of investment/financial practice. To enroll in the program, a
candidate must hold a bachelor’s degree.
®
®
certification is granted by Certified Financial Planner Board of Standards, Inc. (“CFP
**The CFP
Board”). To attain the certification, the candidate must complete the required educational,
examination, experience and ethics requirements set forth by CFP Board. Certain designations, such
as the CPA, CFA and others may satisfy the education component, and allow a candidate to sit for the
Certification Examination. A comprehensive examination tests the candidate’s ability to apply
CFP
financial planning knowledge to client situations. Qualifying work experience is also required for
certification. Qualifying experience includes work in the area of the delivery of the personal financial
planning process to clients, the direct support or supervision of others in the personal financial
®
planning process, or teaching all, or any portion, of the personal financial planning process. CFP
professionals must complete 30 hours of continuing education accepted by CFP Board every two
Item 3 - Disciplinary Information
years.
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Lloyd has no such disciplinary
Item 4 - Other Business Activities
information to report.
Lloyd is not engaged in any other business activities.
Item 5 - Additional Compensation
Lloyd has no other income or compensation to disclose.
Item 6 – Supervision
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Lloyd and
may be reached at (404) 815-5050.
Exhibit A-16
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Carey S. Blakley, CFA
®
CRD# 7446075
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
August 19, 2025
This Brochure Supplement provides information about Carey Blakley, and supplements the Nicholas
Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Carey is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Carey Blakley (year of birth 1988) is a Senior Manager, Portfolios and Allocations for NHCO. His
responsibilities include general development of the firm’s investment platform with a particular
focus on real estate and public equities, providing oversight and guidance to our client reporting
team, and strategic planning for business initiatives involving technology solutions.
Prior to joining NHCO in 2014, Carey was a full-time student, delivery driver, and construction
contractor.
designation* in 2021.
Carey earned a Bachelor of Business Administration from the Georgia Institute of Technology in
®
2014. He received his Chartered Financial Analyst
®
®
(“CFA
”) designation is a professional designation given by the
* The Chartered Financial Analyst
CFA Institute that measures the competence and integrity of financial analysts. The CFA Program is
a graduate-level self-study program that combines a broad-based curriculum of investment
Exhibit A-17
principles with professional conduct requirements. Candidates are required to pass three levels of
examinations covering areas such as accounting, economics, ethics, money management and security
analysis. Before a candidate is eligible to become a CFA charterholder, he/she must meet minimum
experience requirements in the area of investment/financial practice. To enroll in the program, a
Item 3 - Disciplinary Information
candidate must hold a bachelor’s degree.
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Carey has no such disciplinary
information to report.
Item 4 - Other Business Activities
Carey is not engaged in any other business activities.
Item 5 - Additional Compensation
Item 6 – Supervision
Carey has no other income or compensation to disclose.
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Carey and
may be reached at (404) 815-5050.
Exhibit A-18
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Jeffrey S. Buck, CFA
®
CRD# 2239235
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
August 19, 2025
This Brochure Supplement provides information about Jeffrey S. Buck, and supplements the Nicholas
Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Jeffrey is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Jeffrey (“Jeff”) S. Buck (year of birth 1966) joined NHCO in 2021 as a Senior Investment Advisor with
responsibilities including client account management and participation in developing the firm’s
investment platform, primarily in private income. Jeff works with clients on investment strategy and
allocation, strategic planning, and cash flow management. Jeff has over 30 years of financial market
experience; providing manager selection, portfolio construction, and asset allocation in close
collaboration with clients and client teams.
Prior to joining Nicholas Hoffman & Company, Jeff was a partner at Diversified Trust Company, a
southeastern based Private Trust Company, for 10 years where he was first an investment generalist
before being promoted to Director of Diversifiers. In 2020, Jeff additionally took over lead of the
firm’s Asset Allocation. Prior to that, Jeff worked at several firms, primarily in the southeast, as a
senior investment team professional, including as lead Portfolio Manager for the hedge fund of funds
at Wilmington Trust Company, and Chief Investment Officer at Homrich Berg in Atlanta.
Exhibit A-19
®
designation* and is a member of the CFA Institute and the CFA Society Atlanta.
Jeff earned a Bachelor of Arts in Economics from Syracuse University. He holds the Chartered
Financial Analyst
In addition to raising their two sons, he and his wife have served as foster parents.
®
®
(“CFA
”) designation is a professional designation given by the
* The Chartered Financial Analyst
CFA Institute that measures the competence and integrity of financial analysts. The CFA Program is
a graduate-level self-study program that combines a broad-based curriculum of investment
principles with professional conduct requirements. Candidates are required to pass three levels of
examinations covering areas such as accounting, economics, ethics, money management and security
analysis. Before a candidate is eligible to become a CFA charterholder, he/she must meet minimum
experience requirements in the area of investment/financial practice. To enroll in the program, a
candidate must hold a bachelor’s degree.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Jeff has no such disciplinary information
to report.
Item 4 - Other Business Activities
Jeff is not engaged in any other business activities.
Item 5 - Additional Compensation
Item 6 – Supervision
Jeff has no other income or compensation to disclose.
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Jeff and
may be reached at (404) 815-5050.
Exhibit A-20
Brochure Supplement
Form ADV Part 2B
Item 1
Cover Page
-
Nirvanna Silva Novelo, CFP®
CRD# 7888895
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
August 19, 2025
This Brochure Supplement provides information about Nirvanna Silva Novelo, and supplements the
Nicholas Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that
Brochure. Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have
any questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Nirvanna is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Nirvanna Silva Novelo (year of birth 1994) is a Family Office and Investment Advisor of NHCO with
responsibilities that include account management and financial advice. Nirvanna works with clients
on investment strategy and allocation, strategic planning, and cash flow management. Nirvanna is
also intimately involved in the Family Office division of NHCO, with responsibilities that help develop
our clients’ philanthropic endeavors and property management. Nirvanna has been with NHCO since
May 2016.
Nirvanna was born and raised in Mexico City. She received her undergraduate degree in Business
and Organizational Leadership from Brevard College in 2016 and passed the Series 65 – Uniform
Investment Adviser Law Exam in May 2022. Nirvanna became a Certified Financial Planner™
professional in 2024.*
Exhibit A-21
Nirvanna lives in the Vinings neighborhood of Atlanta. She is an avid tennis player and is fluent in
Spanish.
®
®
certification is granted by Certified Financial Planner Board of Standards, Inc. (“CFP
* The CFP
Board”). To attain the certification, the candidate must complete the required educational,
examination, experience and ethics requirements set forth by CFP Board. Certain designations, such
as the CPA, CFA and others may satisfy the education component, and allow a candidate to sit for the
Certification Examination. A comprehensive examination tests the candidate’s ability to apply
CFP
financial planning knowledge to client situations. Qualifying work experience is also required for
certification. Qualifying experience includes work in the area of the delivery of the personal financial
planning process to clients, the direct support or supervision of others in the personal financial
®
planning process, or teaching all, or any portion, of the personal financial planning process. CFP
professionals must complete 30 hours of continuing education accepted by CFP Board every two
years.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Nirvanna has no such disciplinary
information to report.
Item 4 - Other Business Activities
Item 5 - Additional Compensation
Nirvanna is not engaged in any other business activities.
Item 6 - Supervision
Nirvanna has no other income or compensation to disclose.
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Nirvanna
and may be reached at (404) 815-5050.
Exhibit A-22
Brochure Supplement
Form ADV Part 2B
Item 1
Cover Page
-
Aaron F. Jeffries
CRD# 5425987
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
August 19, 2025
This Brochure Supplement provides information about Aaron Jeffries, and supplements the Nicholas
Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Aaron is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Aaron Frederick Jeffries (year of birth 1982) is an Investment Advisor for NHCO with responsibilities
including client account management and service. He works with clients on investment
strategy, allocation and planning.
Aaron has 15 years of financial services experience. Prior to joining NHCO in 2025, Aaron worked at
SunTrust Investment Services Private Wealth Management focusing on fixed income and equity-
linked structured products.
He was born and raised in Indianapolis. Aaron moved to Atlanta to attend Emory University where
he graduated with a BA in Economics. In 2011, he completed the Chartered Alternative Investment
Analyst program and became a CAIA® charterholder* but no longer maintains the certificate. Most
recently he spent time as a stay-at-home Dad to his two young children.
*Chartered Alternative Investment Analyst (“CAIA”) – The CAIA Program is designed to facilitate self-
directed learning for today’s busy professionals through a comprehensive set of readings on risk-
Exhibit A-23
return attributes of institutional quality alternative assets. Candidates’ knowledge is assessed
through exams, administered globally at computerized testing centers. The program is organized into
two levels of study; the Level I and Level II exams are offered twice each year, in March and
September, giving candidates the opportunity to earn the CAIA 3 Charter within a single year. CAIA
candidates must pass both Level I and Level II of the CAIA exam to qualify for the CAIA Charter. Once
a qualified candidate completes the CAIA Program, he or she is eligible for CAIA membership.
Professional experience includes full time employment in a professional capacity within the bank
regulatory, banking, financial, or related fields. CAIA Charter Holders must have over one year of
professional experience and a U.S. bachelor’s degree (or equivalent) or four years of professional
experience.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Aaron has no such disciplinary
information to report.
Item 4 - Other Business Activities
Item 5 - Additional Compensation
Aaron is not engaged in any other business activities.
Item 6 - Supervision
Aaron has no other income or compensation to disclose.
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Aaron and
may be reached at (404) 815-5050.
Exhibit A-24
Brochure Supplement
Form ADV Part 2B
Item 1
Cover Page
-
Cole W. Kliphouse
CRD# 8145588
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
August 19, 2025
This Brochure Supplement provides information about Cole Kliphouse, and supplements the
Nicholas Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that
Brochure. Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have
any questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Cole is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Cole William Kliphouse (year of birth 2000) is a Senior Analyst and Investment Adviser
Representative at NHCO. In his role, Cole supports clients across a range of financial services,
including private investments, portfolio construction, cash flow management, and long-term
financial planning. He also supports the growth of NHCO’s private real estate platform by
underwriting and conducting due diligence on prospective investments, as well as monitoring the
performance of active holdings.
Cole has over three years of experience in the financial services industry. He joined NHCO in 2022
after earning a Bachelor of Arts in Economics with a minor in Financial Management from Clemson
University.
Originally from Alpharetta, Georgia, Cole is passionate about entrepreneurship and community
involvement, particularly working with individuals with special needs. In his free time, he enjoys
fishing, snowboarding, golfing, and spending time outdoors.
Exhibit A-25
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Cole has no such disciplinary
information to report.
Item 4 - Other Business Activities
Cole is not engaged in any other business activities.
Item 5 - Additional Compensation
Item 6 - Supervision
Cole has no other income or compensation to disclose.
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Cole and
may be reached at (404) 815-5050.
Exhibit A-26