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Solutions 4 Wealth, Ltd
566 North Kimball Ave, Suite 120
Southlake, TX 76092
Donald L. Hatcher: 817-934-7010
donny@solutions4wealth.com
www.Solutions4Wealth.com
November 14, 2025
This brochure provides information about the qualifications and business practices of
Solutions 4 Wealth, Ltd. If you have any questions about the contents of this brochure,
please contact Mr. Hatcher at 817-934-7010 and/or donny@solutions4wealth.com. The
information in this brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority. Registration
does not imply a certain level of skill or training.
Additional information about Solutions 4 Wealth, Ltd. (CRD no. 143248) also is available
on the SEC’s website at www.adviserinfo.sec.gov.
Item 2: Material Changes
Annual Update
Form ADV Part 2 requires registered investment advisers to amend their brochure when
information becomes materially inaccurate. If there are any material changes to an adviser’s
disclosure brochure, the adviser is required to notify clients and provide a description of the
material changes. Generally, the Firm will notify clients of material changes on an annual
basis. However, where the Firm determines that an interim notification is either meaningful or
required, the Firm will notify our clients promptly. In either case, the Firm will notify our clients
in a separate document.
Material Changes since the Last Annual Update
The last annual filing of the Firm Brochure dated March 31, 2025 has been updated as of
November 14, 2025. There are no material changes to report since the last update. However,
Prestige Finance Company was closed and is no longer active.
Additionally, we have made other changes throughout this brochure, some of which may
clarify or enhance existing disclosures including our model portfolios and private investments,
but we do not consider these other changes to be material.
Full Brochure Available
The revised Firm Brochure will be available since our last delivery or posting of this Disclosure
Brochure on the SEC’s public disclosure website (IAPD) at www.adviserinfo.sec.gov or clients
may contact our office at the number or by email listed on the cover page of this Disclosure
Brochure to obtain a copy. When an update is made to this Disclosure Brochure, Solutions 4
Wealth will send a copy to clients with the summary of material changes, or a summary of
material changes that includes an offer to send clients a copy [either by electronic means
(email) or in hard copy form].
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Item 3: Table of Contents
Cover Page ................................................................................................................................ 1
Item 2: Material Changes ........................................................................................................... 2
Annual Update ....................................................................................................................... 2
Material Changes since the Last Annual Update .................................................................. 2
Full Brochure Available .......................................................................................................... 2
Item 3: Table of Contents .......................................................................................................... 3
Item 4: Advisory Business ......................................................................................................... 5
Firm Description .................................................................................................................... 5
Types of Advisory Services ................................................................................................... 5
Client Tailored Services and Client Imposed Restrictions ..................................................... 7
Wrap Fee Programs .............................................................................................................. 7
Client Assets Under Management ......................................................................................... 7
Item 5: Fees and Compensation ............................................................................................... 7
Method of Compensation and Fee Schedule ........................................................................ 7
Client Payment of Fees ......................................................................................................... 8
Additional Client Fees Charged ............................................................................................. 9
Prepayment of Client Fees .................................................................................................... 9
External Compensation for the Sale of Securities to Clients ...................................................... 9
Item 6: Performance-Based Fees and Side-By-Side Management .......................................... 9
Sharing of Capital Gains ........................................................................................................ 9
Item 7: Types of Clients ............................................................................................................ 9
Description ............................................................................................................................. 9
Account Minimums .............................................................................................................. 10
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .................................... 10
Methods of Analysis ............................................................................................................ 10
Investment Strategy ............................................................................................................. 10
Security Specific Material Risks .......................................................................................... 10
Item 9: Disciplinary Information ............................................................................................... 13
Criminal or Civil Actions ....................................................................................................... 13
Administrative Enforcement Proceedings ............................................................................ 13
Self- Regulatory Organization Enforcement Proceedings ................................................... 13
Item 10: Other Financial Industry Activities and Affiliations .................................................... 13
Broker-Dealer or Representative Registration ..................................................................... 13
Futures or Commodity Registration ..................................................................................... 13
Material Relationships Maintained by this Advisory Business and Conflicts of Interest ...... 13
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ... 14
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
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................................................................................................................................................ 15
Code of Ethics Description .................................................................................................. 15
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest ................................................................................................................................. 15
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest ................................................................................................................................. 16
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Transactions and Conflicts of Interest ................................................................................. 16
Item 12: Brokerage Practices .................................................................................................. 16
Factors Used to Select Broker-Dealers for Client Transactions .......................................... 16
Aggregating Securities Transactions for Client Accounts .................................................... 18
Item 13: Review of Accounts ................................................................................................... 19
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons
Involved ............................................................................................................................... 19
Review of Client Accounts on Non-Periodic Basis .............................................................. 19
Content of Client Provided Reports and Frequency ............................................................ 19
Item 14: Client Referrals and Other Compensation ................................................................ 19
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of
Interest ................................................................................................................................. 19
Advisory Firm Payments for Client Referrals ....................................................................... 19
Item 15: Custody ..................................................................................................................... 19
Account Statements ............................................................................................................ 19
Item 16: Investment Discretion ................................................................................................ 20
Discretionary Authority for Trading ...................................................................................... 20
Item 17: Voting Client Securities ............................................................................................. 20
Proxy Votes ......................................................................................................................... 20
Item 18: Financial Information ................................................................................................. 20
Balance Sheet ..................................................................................................................... 20
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients ...................................................................................................... 20
Bankruptcy Petitions during the Past Ten Years ................................................................. 20
Item 19: Requirements for State Registered Advisors ............................................................ 20
Principal Executive Officers and Management Persons ...................................................... 20
Outside Business Activities ................................................................................................. 20
Performance Based Fee Description ................................................................................... 21
Disclosure of Material Facts Related to Arbitration or Disciplinary Actions Involving
Management Persons ......................................................................................................... 21
Material Relationship Maintained by this Advisory Business or Management persons with
Issuers of Securities ............................................................................................................ 21
Material Conflicts of Interest Assurance .............................................................................. 21
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Item 4: Advisory Business
Firm Description
While Solutions 4 Wealth, Ltd. (“S4W” or the “Firm”) has been in business since September
2002, it has been a Registered Investment Advisor at either the state or federal level since
2007. The principal owners are Donald Hatcher and Melissa Hatcher.
through determining
Types of Advisory Services
ASSET MANAGEMENT
S4W only offers discretionary asset management services to advisory Clients. S4W will
offer Clients ongoing asset management services
individual
investment goals, time horizons, objectives, and risk tolerance. Investment strategies,
investment selection, asset allocation, portfolio monitoring, and the overall investment
program will be based on the above factors. The Client will authorize S4W discretionary
authority to execute selected investment program transactions as stated within the
Investment Advisory Agreement.
Discretionary
When the Client provides S4W discretionary authority, the Client will sign a limited trading
authorization or equivalent. S4W will have the authority to execute transactions in the
account without seeking Client approval for each transaction.
This service is designed to allow clients access to professional portfolio management that
is normally available only to larger institutional investors. The Firm selects appropriate
outside funds for each asset class in the client’s portfolio.
Employees associated with the Firm may direct their clients to insurance companies which
sell variable annuity products. In turn, the Firm may manage the underlying investment in
the variable annuity and receive compensation directly from the client for this service. This
compensation is based on the Investment Advisory Services fee schedule as shown below.
Model Portfolios
A model portfolio is a pre-designed investment strategy with a specific asset allocation (like
a mix of stocks and bonds) used to manage client accounts. The Firm designs model
portfolios that align with the Client’s objectives based on historical performance and ratings
from various third-party sources such as Morningstar. The models are reviewed at least
annually for performance and ratings changes but more often if needed. Client objectives
are based on the Client’s responses to the Client Suitability Information Form and Risk
Questionnaire. The Firm maintains discretionary authority to manage the Client’s portfolio,
meaning the Firm can execute trades to keep the Client’s investments consistent with the
Client’s stated goals and risk tolerance without seeking the Client’s permission for every
transaction. Clients will often maintain multiple objectives simultaneously for a single
account. In these instances, the Firm will assign the model that fits the majority of the assets
held in the account while adding positions that are designed to meet the additional
objectives.
The Firm does not select or recommend individual securities in client accounts but will
discuss such investments with Clients and make such executions on their behalf upon
request. For individual stock positions, if the client directs the Firm to buy and hold the
position, the Firm will exclude that position from billable AUM. However, if the client directs
the Firm to monitor the account so as to buy and or sell additional shares given defined
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parameters, the position will be included as billable AUM.
The Firm will select the model portfolio(s) and reallocate funds from or to the model
portfolio(s) and funds in other accounts over which the Firm has discretionary authority.
Investments are automatically rebalanced to keep the portfolio's asset allocation aligned
with the Clients’ target risk profile. There are other model portfolios not recommended by
our Firm that could be appropriate for Clients and are less costly than those recommended
by our Firm. There are no guarantees that the Clients’ financial goals or objectives will be
achieved through the model portfolio program or by a recommended/selected model
portfolio. Further, no performance guarantee can ever be offered by our Firm.
FINANCIAL PLANNING
S4W also may provide financial planning services for clients as needed. A financial plan is
designed to meet each client’s requirements and may entail a fully documented plan
covering a range of needs or may address a specific concern, such as insurance review
and coverage, tax planning, retirement, or college funding, etc.
If the Client elects to act on any of the recommendations, the Client is under no obligation
to effect the transaction through S4W. Financial plans will be completed and delivered within
ninety (90) days contingent upon timely delivery of all required documentation.
PRIVATE FUND INVESTMENTS
This is not an offer to sell an interest in any fund managed by S4W.
S4W Fund Advisors, LLC, an affiliate of S4W organized the S4W Multifamily Housing Fund,
LP as a pooled investment vehicle to facilitate investment by a number of qualified Clients
into the real estate sector. S4W Multifamily Housing Fund GP LLC is the General Partner
and S4W is the investment adviser to this private fund. The governing documents contain
additional information and should be reviewed prior to investment.
Occasionally, S4W provides advice, due diligence and/or ongoing monitoring of private
investments in evaluating whether these types of investments are suitable for investors.
Before any Private Placement is presented to a client, the Firm will conduct due diligence
on the company’s senior managers, including in-person discussions regarding general
business practices, prior project outcomes, and review the specifics of the current offering.
Private Placements are inherently illiquid. The Firm will typically limit these offerings to
accredited investors and place no more than 5% of the clients’ investable assets in any
single offering.
IRA ROLLOVER RECOMMENDATIONS
For the purpose of complying with the DOL's Prohibited Transaction Exemption 2020-02
("PTE 2020-02"), when applicable, we are providing the following acknowledgment to
clients. When we provide investment advice to clients regarding their retirement plan
account or individual retirement account, we are a fiduciary within the meaning of Title I of
the Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. The way we make money
creates some conflicts with your interests, so we operate under an exemption that requires
us to act in the clients’ best interest and not put our interest ahead of the clients. Under this
exemption, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice),
financial
interests ahead of
the clients when making
• Never put our
recommendations (give loyal advice),
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• Avoid misleading statements about conflict of interests, fees, and investments,
• Follow policies and procedures designed to ensure that we give advice that is in the
clients’ best interest,
• Charge no more than is reasonable for our services, and
• Give the clients basic information about conflict of interests.
We benefit financially from the rollover of the clients’ assets from a retirement account to an
account that we manage or provide investment advice, because the assets increase our
assets under management and, in turn, our advisory fees. As a fiduciary, we only
recommend a rollover when we believe it is in the clients’ best interest.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each Client are documented in our Client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
restrictions on investing in certain securities or types of securities.
Agreements may not be assigned without written Client consent.
Wrap Fee Programs
S4W does not sponsor any wrap fee programs.
Client Assets Under Management
As of December 31, 2024, S4W had approximately $1,696,362 in non-discretionary assets
under management and $171,895,666 discretionary assets under management.
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
ASSET MANAGEMENT
The fee schedule (not including planning fees) for the Firm’s management of Client’s
portfolio investments on a stand-alone basis follows. This fee is negotiable and may include
planning fees and/or specific S4W named products. All accounts are aggregated within a
household, with the exception of a Client’s investment in the Fund, if any, as detailed under
“Private Fund Investments” in Item 5, to determine the fee.
Portion of Investment Portfolio*
Up to $4,000,000
Next $4,000,001 to $6,000,000
Next $6,000,001 to $10,000,000
Next$10,000,001 or more
Annual Rate
1.0%
0.75%
0.60%
0.50%
*Annual Minimum fee is $1,500
Firm investment management fees are billed quarterly in advance at the rate of one-fourth
of the annual fee shown above and are typically deducted from clients’ accounts. Fees for
a quarter are calculated based on the portfolio valuation as determined by the account
custodian on a daily basis during the prior quarter. If a client opens an account during a
quarter, fees will be calculated based on the original transfer amount and will be assessed
on a pro-rata basis when the assets are transferred into a Firm managed account. Lower
fees for comparable services may be available from other sources. Clients may terminate
their account within five (5) business days of signing the Investment Advisory Agreement
with no obligation and without penalty. Otherwise, Clients may terminate advisory services
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with thirty (30) days written notice. In the case of a variable annuity, the initial fee will be
assessed when the annuity is funded.
FINANCIAL PLANNING
Fees for financial planning may be included in the investment advisory fee as stated above
or may be charged in addition to investment management fees. If charged in addition to the
investment management fees, a mutually agreed-upon fixed fee is assessed. In this case,
the fee is determined after defining the scope of work required, the level of personnel to
complete the work and the expected time to complete the required work.
One-half of the plan fee is due upon execution of the Investment Advisory Agreement, with
the remainder due upon presentation of the completed plan material (maximum fee is
$10,000). Client may cancel within five (5) business days of signing Agreement with no
obligation and without penalty. If the Client cancels after five (5) business days, any
unearned fees will be refunded to the Client, or any unpaid earned fees will be due to S4W.
It is possible that Clients receiving the same service from the Firm will pay different fees.
Fees for the S4W named products listed under “Advisory Services” above may be included
in the financial planning or investment management fee or may be charged separately,
depending upon the complexity of the client’s situation. If a client opts for the use of the
S4W named products, the fixed fee for the combined products is due upon receipt of the
service (maximum fee is $10,000).
PRIVATE FUND INVESTMENTS
S4W Multifamily Housing Fund (S4W MFHF)
S4W MFHF bears all costs of its organization and operation, expenses incurred in the
purchase and sale of investments, and accounting and audit fees. For further details,
please see the governing documents for the Fund.
S4W receives a 1.75% investment management fee annually for the Fund. The fee is
calculated quarterly in advance and charged mid-quarter by deduction from each investor’s
capital account balance.
The value of the Client’s investment in the Fund is not included in the Investment Portfolio
total assets under management and is not charged the investment management fee
outlined in the Client’s client agreement.
Private Investments
Occasionally, the Firm provides advice, due diligence and/or ongoing monitoring of private
investments. Fees for these services are charged based on the initial capital investment.
Valuations may be adjusted downward based on the periodic project updates provided by
the offeror if there is substantive concern regarding the ability of the offeror to return the
initial capital. The value of the private investments is included in the billable AUM and fees
are calculated per the agreed schedule.
Client Payment of Fees
Investment management fees are billed quarterly in advance, meaning that we invoice you
at the beginning of the billing period. Fees are usually deducted from a designated Client
account to facilitate billing. The Client must consent in advance to direct debiting of the
Firm’s investment advisory fees from their investment account.
Fees for financial plans are billed 50% in advance with the balance due upon plan delivery.
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S4W, in its sole discretion, may charge a different investment advisory fee based upon
certain criteria (e.g., historical relationship, type of assets, anticipated future earning
capacity, anticipated future assets, dollar amounts of assets to be managed, related
accounts, account composition, negotiations with Clients, estate complexity, etc.).
Additional Client Fees Charged
Custodians may charge transaction fees on purchases or sales of certain mutual funds,
equities, and exchange-traded funds (“ETFs”). These charges may include mutual fund
transaction fees, postage and handling and miscellaneous fees.
For more details on the brokerage practices, see Item 12 of this brochure.
Prepayment of Client Fees
S4W does not require any prepayment of fees of more than $1,200 per Client and six months
or more in advance.
Fees for financial plans are billed 50% in advance with the balance due upon plan delivery.
If the Client cancels after five (5) business days, any unearned fees will be refunded to the
Client, or any unpaid earned fees will be due to S4W.
External Compensation for the Sale of Securities to Clients
S4W does not receive any external compensation for the sale of securities to Clients, nor
do any of the investment advisor representatives (“IARs”) of S4W
Item 6: Performance-Based Fees and Side-By-Side
Management
Sharing of Capital Gains
Neither S4W, their affiliates, nor the Private Fund charge performance-based fees to
Clients.
“Side-by-Side Management” refers to a situation in which a firm manages some accounts
that are billed based on a percentage of assets under management and manages other
accounts that are assessed on a performance fee basis. Because S4W has no
performance-based fee accounts, it has no side-by-side management conflicts.
Item 7: Types of Clients
Description
The Firm provides investment supervisory services and manages investment advisory
accounts for:
Individuals
•
• High net worth individuals (greater than $1M excluding primary residence of
investable assets or $2.1 million net worth)
• Pension and profit-sharing plans
• Trusts, estates
• Partnerships
• Private funds
Client relationships vary in scope and length of service.
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Account Minimums
The Firm does not require a minimum account size for investment management. However,
S4W requires a minimum investment commitment of $150,000 from investors in the S4W
Multifamily Housing Fund, LP.
Item 8: Methods of Analysis, Investment Strategies and Risk
of Loss
Methods of Analysis
The Firm begins with solid academic research. The Firm’s philosophy is grounded in the
belief that markets are efficient and that managers cannot consistently pick stocks that will
outperform their comparable market. The Firm mirrors the market with a diversified portfolio
of 12,000 plus companies and a broad coverage of asset classes. By utilizing more than
ten investment portfolios, the Firm can match a client to a desired investment risk and
successfully capture what the markets have to offer. These time-tested strategies allow the
Firm to provide portfolios that minimize tax impacts, expenses, and risks, while attempting
to maximize return. The portfolio strategies and consequent asset allocations are structured
to meet clients’ investment objectives, risk tolerance and investing time horizons. Risks for
each strategy vary according to the individual security types and investments selected and
the frequency of trading. Generally, the Firm adheres to a “buy and hold” philosophy overall,
minimizing transaction costs and account turnover. This philosophy will mean accounts are
likely to miss short-term market swings whether up or down.
The Firm does not guarantee the future performance of the account or any specific level of
performance, the success of any investment decision or strategy that the Firm may use, or
the success of the Firm’s overall management of the account. The client understands that
investment decisions made for the client’s account by the Firm are subject to various
market, currency, economic, political, and business risks, and that those investment
decisions will not always be profitable. Clients are reminded that investing in any security
entails risk of loss which they should be willing to bear.
Investment Strategy
The investment strategy for a specific Client is based upon the investment objectives stated
by the Client during consultations. The Client may change these objectives at any time by
providing written notice to S4W. Each Client executes a Client profile form or a similar form
that documents their objectives and their desired investment strategy.
Security Specific Material Risks
All investment programs have certain risks that are borne by the investor. Our investment
approach constantly keeps the risk of loss in mind. Investors face the following investment
risks and should discuss these risks with S4W:
• Market Risk: The prices of securities held by mutual funds in which Clients invest
may decline in response to certain events taking place around the world, including
those directly involving the companies whose securities are owned by a fund;
conditions affecting the general economy; overall market changes; local, regional, or
global political, social, or economic instability; and currency, interest rate and
commodity price fluctuations. Investors should have a long-term perspective and be
able to tolerate potentially sharp declines in market value.
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become
less attractive, causing their market values to decline.
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•
Inflation Risk: When any type of inflation is present, a dollar today will buy more than
a dollar next year, because purchasing power is eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the
dollar against the currency of the investment’s originating country. This is also
referred to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments may have
to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily
relates to fixed income securities.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties
are not.
• Management Risk: The advisor’s investment approach may fail to produce the
intended results. If the advisor’s assumptions regarding the performance of a
specific asset class or fund are not realized in the expected time frame, the overall
performance of the Client’s portfolio may suffer.
lower
• Equity Risk: Equity securities tend to be more volatile than other investment choices.
The value of an individual mutual fund or ETF can be more volatile than the market
as a whole. This volatility affects the value of the Client’s overall portfolio. Small- and
mid-cap companies are subject to additional risks. Smaller companies may
experience greater volatility, higher failure rates, more limited markets, product lines,
financial resources, and less management experience than larger companies.
Smaller companies may also have a
trading volume, which may
disproportionately affect their market price, tending to make them fall more in
response to selling pressure than is the case with larger companies.
•
Investment Companies Risk: When a Client invests in open-end mutual funds or
ETFs, the Client indirectly bears their proportionate share of any fees and expenses
payable directly by those funds. Therefore, the Client will incur higher expenses,
which may be duplicative. In addition, the Client’s overall portfolio may be affected
by losses of an underlying fund and the level of risk arising from the investment
practices of an underlying fund (such as the use of derivatives). ETFs are also
subject to the following risks: (i) an ETF’s shares may trade at a market price that is
above or below their net asset value or (ii) trading of an ETF’s shares may be halted
if the listing exchange’s officials deem such action appropriate, the shares are de-
listed from the exchange, or the activation of market-wide “circuit breakers” (which
are tied to large decreases in stock prices) halts stock trading generally. Adviser has
no control over the risks taken by the underlying funds in which Client invests.
• Emerging markets have been more volatile than the markets of developed countries
with more mature economies.
• Private Equity/Placement Risk: Because offerings are exempt from registration
requirements, no regulator has reviewed the offerings to make sure the risks
associated with the investment and all material facts about the entity raising money
are adequately disclosed. Securities offered through private placements are
generally illiquid, meaning there are limited opportunities to resell the security. The
risk of the underlying investment may be significantly higher than publicly traded
investments.
• Legal and Regulatory Matters Risks: Legal developments which may adversely
impact investing and investment-related activities can occur at any time. “Legal
Developments” means changes and other developments concerning foreign, as well
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as US federal, state and local laws and regulations, including adoption of new laws
and regulations, amendment or repeal of existing laws and regulations, and changes
in enforcement or interpretation of existing laws and regulations by governmental
regulatory authorities and self-regulatory organizations (such as the SEC, the US
Commodity Futures Trading Commission, the Internal Revenue Service, the US
Federal Reserve and the Financial Industry Regulatory Authority). Our management
of accounts may be adversely affected by the legal and/or regulatory consequences
of transactions effected for the accounts. Accounts may also be adversely affected
by changes in the enforcement or interpretation of existing statutes and rules by
governmental regulatory authorities or self-regulatory organizations.
• System Failures and Reliance on Technology Risks: Our investment strategies,
operations, research, communications, risk management, and back-office systems
rely on technology, including hardware, software, telecommunications, internet-
based platforms, and other electronic systems. Additionally, parts of the technology
used are provided by third parties and are, therefore, beyond our direct control. We
seek to ensure adequate backups of hardware, software, telecommunications,
internet-based platforms, and other electronic systems, when possible, but there is
no guarantee that our efforts will be successful. In addition, natural disasters, power
interruptions and other events may cause system failures, which will require the use
of backup systems (both on- and off-site). Backup systems may not operate as well
as the systems that they back up and may fail to properly operate, especially when
used for an extended period. To reduce the impact a system failure may have, we
continually evaluate our backup and disaster recovery systems and perform periodic
checks on the backup systems’ conditions and operations. Despite our monitoring,
hardware, telecommunications, or other electronic systems malfunctions may be
unavoidable, and result in consequences such as the inability to trade for or monitor
client accounts and portfolios. If such circumstances arise, the Investment
Committee will consider appropriate measures for clients.
• Cybersecurity Risk: A portfolio is susceptible to operational and information security
risks due to the increased use of the internet. In general, cyber incidents can result
from deliberate attacks or unintentional events. Cyberattacks include, but are not
limited to, infection by computer viruses or other malicious software code, gaining
unauthorized access to systems, networks, or devices through “hacking” or other
means for the purpose of misappropriating assets or sensitive information,
corrupting data, or causing operational disruption. Cybersecurity failures or
breaches by third-party service providers may cause disruptions and impact on the
service providers’ and our business operations, potentially resulting in financial
losses, the inability to transact business, violations of applicable privacy and other
laws, regulatory fines, penalties, reputational damage, reimbursement, or other
compensation costs, and/or additional compliance costs. While we have established
business continuity plans and risk management systems designed to prevent or
reduce the impact of such cyberattacks, there are inherent limitations in such plans
and systems due in part to the everchanging nature of technology and cyberattack
tactics.
• Pandemic Risks: The outbreak of the novel coronavirus rapidly became a pandemic
and has resulted in disruptions to the economies of many nations, individual
companies, and the markets in general, the impact of which cannot necessarily be
foreseen at the time. This created closed borders, quarantines, supply chain
disruptions and general anxiety, negatively impacting global markets in an
unforeseeable manner. The impact of the novel coronavirus and other such future
infectious diseases in certain regions or countries may be greater or less due to the
nature or level of their public health response or due to other factors. Health crises
Page | 12
caused by the coronavirus outbreak and future infectious diseases may exacerbate
other pre-existing political, social, and economic risks in certain countries. The
impact of such health crises may be quick, severe and of unknowable duration.
These pandemics and other epidemics and pandemics that may arise in the future
could result in continued volatility in the financial markets and could have a negative
impact on investment performance.
The above list of risk factors is not intended to be a complete list or explanation of the risks
involved in an investment strategy. You are encouraged to consult your financial advisor,
legal counsel, and tax professional on an initial and continuous basis in connection with
selecting and engaging in the services S4W provides. In addition, due to the dynamic nature
of investments and markets, strategies may be subject to additional and different risk factors
not discussed above.
Item 9: Disciplinary Information
Criminal or Civil Actions
S4W and its management have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
S4W and its management have not been involved in administrative enforcement
proceedings.
Self- Regulatory Organization Enforcement Proceedings
S4W and its management have not been involved in legal or disciplinary events that are
material to a Client’s or prospective Client’s evaluation of S4W or the integrity of its
management.
Item 10: Other Financial Industry Activities and Affiliations
As described in Item 4 above, S4W is the investment adviser to a private fund. Refer for
Items 4 and 5 for details.
Broker-Dealer or Representative Registration
S4W is not registered as a broker-dealer and no affiliated IARs of S4W are registered
representatives of a broker-dealer.
Futures or Commodity Registration
Neither S4W nor its affiliated representatives are registered or have an application pending
to register as a futures commission merchant, commodity pool operator, or a commodity
trading advisor.
Material Relationships Maintained by this Advisory Business and Conflicts of
Interest
Donald Hatcher has a financial affiliated business as an insurance agent and owner of
Advanced Planning, Inc. Approximately 25% of his time is spent on these activities. He will
offer Clients services from those activities. As an insurance agent, he may receive separate
yet typical compensation.
Prestige Consulting Group LLC (PCG) is a Texas limited liability company owned and
managed by Donald Hatcher, and he receives compensation for managerial services
provided to PCG. PCG provides real estate consulting, financial advice, and property
management to various parties. A reasonable fee for services will be billed on a project-by-
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property basis. PCG may also enter into side letter agreements with private placement
companies, private equity groups, venture capital companies, limited partnerships, and
startup LLCs to raise capital to further each group's business interests. PCG is paid a
placement fee and may be awarded a percentage of the partnership as separate yet typical
compensation. Approximately 15% of Donald Hatcher’s time is spent on these activities.
These practices represent conflicts of interest because they give an incentive to recommend
products based on the compensation amount received. This conflict is mitigated by
disclosures, procedures, and the Firm’s fiduciary obligation to place the best interest of the
Client first and the Clients are not required to purchase any products. Clients have the option
to purchase these products through another insurance agent of their choosing.
Non-Affiliated Private Funds
1. Chuck’s RV Resort Mabank LP (“Mabank”) October 2022: This limited partnership
(“Fund”) was formed as a single purpose entity to develop and own Chuck’s RV Resort
Mabank. RK Enterprises I, LLC serves as the General Partner (“GP”) of the Fund.
Randy Guy Hatcher is the sole Member and Manager of the GP. The D&M Hatcher
Living Trust, of which Donald Hatcher and his wife serve as Trustees, has made an
investment in the Fund. Therefore, the Trust is a Limited Partner in Mabank. The amount
invested (less than 1.00% of the total Limited Partnership interests) is not considered
material. Neither Donald Hatcher, his wife nor the Trust has any control over the
operations or management of the Fund.
2. Chuck’s Texoma Resort LP March 2025: This limited partnership was formed as a single
purpose entity to develop and own Chuck’s Texoma Resort LP aka The Grove at
Texoma (“The Grove”). Creative Holdings, LLC serves as the General Partner of The
Grove. Randy Guy Hatcher is the President, sole Member and Manager of the GP.
3. Vista Ridge Cottages, LP: This limited partnership was formed as a single purpose entity
to develop and own Vista Ridge Cottages, LP (“Vista”). Possible Blessings, LLC is the
General Partner of Vista. Randy Guy Hatcher is the President, sole Member and
Manager of the GP.
S4W solicits Clients to invest in Mabank, The Grove and Vista (collectively, the “Funds”)
and other private funds provided they are an “accredited investor”, as defined in Rule 501
of Regulation D under the Securities Act of 1933.
Mr. Guy Hatcher is responsible for operational oversight and management of these Funds,
including debt and equity financing, pricing strategy, branding, and operations. There is no
control relationship between Mr. Guy Hatcher’s entities and S4W or any of its associated
persons.
To mitigate conflicts of interest, S4W discloses its relationship/arrangement with these
Funds and other private funds, where applicable, to potential investors through the “Related
Party Disclosures” in the offering documents. If S4W determines that a client fits the criteria
to invest in any of these Funds, and that the investment appears to be in the client’s interest,
a Confidential Private Placement Memorandum (“Memorandum”) will be provided to the
client for consideration. This Memorandum will disclose conflicts of interest and inherent
risks, which are necessary for an investor to make an informed decision. Potential investors
are encouraged to read the Memorandum before accepting S4W’s recommendation to
invest.
Recommendations or Selections of Other Investment Advisors and Conflicts
of Interest
S4W does not select or recommend other investment advisors or have other business
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relationships with those advisors for which S4W receives compensation directly or
indirectly.
include employees and/or
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Code of Ethics Description
The affiliated persons (affiliated persons
independent
contractors) of S4W have committed to a Code of Ethics (“Code”). The purpose of our Code
is to set forth standards of conduct expected of S4W affiliated persons and addresses
conflicts that may arise. The Code defines acceptable behavior for affiliated persons of
S4W. The Code reflects S4W and its supervised persons’ responsibility to act in the best
interest of their Client.
One area which the Code addresses is when affiliated persons buy or sell securities for
their personal accounts and how to mitigate any conflict of interest with our Clients. We do
not allow any affiliated persons to use non-public material information for their personal
profit or to use internal research for their personal benefit in conflict with the benefit to our
Clients.
S4W’s policy prohibits any person from acting upon or otherwise misusing non-public or
inside information. No advisory representative or other affiliated person, officer, or director
of S4W may recommend any transaction in a security or its derivative to advisory Clients or
engage in personal securities transactions for a security or its derivatives if the advisory
representative possesses material, non-public information regarding the security.
S4W’s Code is based on the guiding principle that the interests of the Client are our top
priority. S4W’s officers, directors, advisors, and other affiliated persons have a fiduciary duty
to our Clients and must diligently perform that duty to maintain the complete trust and
confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s
interests over the interests of either affiliated persons or the Firm.
The Code applies to “access” persons. “Access” persons are affiliated persons who have
access to non-public information regarding any Clients' purchase or sale of securities, or
non-public information regarding the portfolio holdings of any reportable fund, who are
involved in making securities recommendations to Clients, or who have access to such
recommendations that are non-public.
S4W will provide a copy of the Code of Ethics to any Client or prospective Client upon
request at their address of record.
Investment Recommendations Involving a Material Financial Interest and
Conflict of Interest
S4W may have conflicts of interest in managing the portfolio of the funds because its
compensation for managing and/or advising other investment vehicles or accounts may
exceed its compensation for managing the portfolio of the funds, thus providing an incentive
to prefer such other investment vehicles or accounts. Moreover, if S4W makes trading
decisions in respect of such investment vehicles or accounts and in respect of the funds at
or about the same time, the funds may be competing with such other investment funds or
accounts for the same or similar positions. S4W will endeavor to allocate all investment
opportunities on a fair and equitable basis between the funds and those other investment
vehicles and accounts.
S4W provides investment advisory services to separately managed accounts of clients that
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may invest in the funds. For such advisory clients, S4W will receive investment
management fees on multiple levels such as advisory fees for advising clients as to their
individual accounts and management fees to be received in connection with investment
management services provided to the funds. This arrangement results in our clients
investing in the funds paying higher fees to us than a person that directly invests in the
funds in the absence of such investment advisory relationship. The right to receive such
additional management fees is a conflict of interest for S4W in that it incentivizes us to direct
S4W clients to invest in the funds. S4W may refund to S4W clients additional fees received
by S4W arising from S4W’s services to the funds, that result from the multiple levels of
management fees for such advisory clients.
Advisory Firm Purchase of Same Securities Recommended to Clients and
Conflicts of Interest
S4W and its affiliated persons may buy or sell securities that are also held by Clients. In
order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated
persons are required to disclose all reportable securities transactions as well as provide
S4W with copies of their brokerage statements.
The Chief Compliance Officer reviews all trades of the affiliated persons each quarter. The
personal trading reviews ensure that the personal trading of affiliated persons does not
affect the markets, and that Clients of the Firm receive preferential treatment over
associated persons’ transactions.
Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
S4W does not maintain a firm proprietary trading account and therefore no conflicts of
interest exist. However, affiliated persons may buy or sell securities at the same time they
buy or sell securities for Clients. In order to mitigate conflicts of interest such as front
running, affiliated persons are required to disclose all reportable securities transactions as
well as provide S4W with copies of their brokerage statements.
The Chief Compliance Officer reviews all employee trades each quarter. The personal
trading reviews ensure that the personal trading of affiliated persons does not affect the
markets, and that Clients of the firm receive preferential treatment over associated persons’
transactions.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
The Firm participates in the Schwab Institutional (SI) services program offered to
independent investment advisors by Charles Schwab & Company, Inc. (“Schwab”), a
FINRA-registered broker-dealer. Clients in need of brokerage and custodial services will
generally have Schwab recommended to them due to Schwab’s:
• Discounted commission structure
• Arrangements with multiple mutual fund families allowing trading through Schwab
• No Fee ETF and Mutual Fund lists
• Financial stability
• Provision of account information online to all clients
• Client service to the Firm and its clients
• Ease of reporting to the Firm and its clients
As part of the SI program, the Firm receives benefits that it would not have received if it did
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not offer investment advice.
Research and Other Soft-Dollar Benefits
Schwab provides the Firm with access to its institutional trading and custody services, which
are typically not available to Schwab retail investors. These services generally are available
to independent investment advisors on an unsolicited basis, at no charge to them so long
as a total of at least $10 million of the advisor’s clients’ assets are maintained in accounts
at Schwab Institutional. These services are not contingent upon the Firm committing to
Schwab any specific amount of business (assets in custody or trading commissions).
Schwab’s brokerage services include the execution of securities transactions, custody,
research, and access to mutual funds and other investments that are otherwise generally
available only to institutional investors or would require a significantly higher minimum initial
investment.
For the Firm’s client accounts maintained in its custody, Schwab generally does not charge
separately for custody services but is compensated by account holders through
commissions or other transaction-related or asset-based fees for securities trades that are
executed through Schwab or that settle into Schwab accounts.
Schwab also makes available to the Firm other products and services that benefit the Firm
but may not directly benefit its clients’ accounts. Many of these products and services may
be used to service all or some substantial number of the Firm’s accounts.
Schwab’s products and services that assist the Firm in managing and administering clients’
accounts include software and other technology that:
• Provide access to client account data (such as trade confirmations and account
statements)
• Facilitate trade execution and allocate aggregated trade orders for multiple client
accounts
• Provide research, pricing, and other market data
• Facilitate payment of the Firm’s fees from its clients’ accounts
• Assist with back-office functions, recordkeeping, and client reporting
Schwab Institutional also offers other services intended to help the Firm manage and further
develop its business enterprise. These services include:
• Compliance, legal and business consulting
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants and insurance
providers.
Schwab may make available, arrange and/or pay third-party vendors for the types of
services rendered to the Firm: Schwab Institutional may discount or waive fees it would
otherwise charge for some of these services or pay all or a part of the fees of a third-party
providing these services to the Firm. Schwab Institutional may also provide other benefits
such as educational events or occasional business entertainment for Firm personnel. In
evaluating whether to require that clients custody their assets at Schwab, the Firm considers
the availability of some of the foregoing products and services and other arrangements as
part of the total mix of factors it considers and not solely the nature, cost or quality of custody
and brokerage services provided by Schwab, which may create a potential conflict of
interest.
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Best Execution
Investment advisors who manage or supervise Client portfolios have a fiduciary obligation
of best execution. The determination of what may constitute best execution and price in the
execution of a securities transaction by a broker involves a number of considerations and
is subjective. Factors affecting brokerage selection include the overall direct net economic
result to the portfolios, the efficiency with which the transaction is effected, the ability to
affect the transaction where a large block is involved, the operational facilities of the broker-
dealer, the value of an ongoing relationship with such broker and the financial strength and
stability of the broker. The Firm does not receive any portion of the trading fees.
Brokerage for Client Referrals
The Firm does not consider, in selecting or recommending broker-dealers, whether the
Firm receives referrals from a broker/dealer or third-party.
Directed Brokerage
Some clients may choose to execute trades through broker-dealers with whom they have
an existing relationship. In this instance, the Firm is less able to meet its fiduciary duty to
obtain best execution for transactions executed for clients. These clients are also unable to
participate in aggregated trade orders. Either of these reasons may cause clients directing
the Firm to use a particular broker to pay more than would otherwise be the case.
Aggregating Securities Transactions for Client Accounts
The Firm will generally aggregate brokerage orders for clients and allocate the securities
purchased or sold among the participating accounts, with each account receiving the same
terms. The proportion in which participating accounts will share transactions will be
determined by the portfolio manager(s) on the basis of investment objectives, cash
availability, expected cash and liquidity needs, and other relevant factors. All clients
participating in each aggregated order shall receive the weighted average price and pay a
trade commission based on the account agreement with the custodian. Smaller accounts
may bear higher charges if they fail to meet the minimum account sizes set by the broker.
The appropriate share amount of each buy or sell of a particular security is determined prior
to placing the trade. Allocations of orders among client accounts must be made in a fair and
equitable manner. Each participating client in an aggregated trade receives the
predetermined number of shares in the trade allocation process. In the unusual event of a
partial fill of an aggregated order, the originally anticipated allocation will be altered in a fair
and equitable manner.
As a rule, allocations among accounts with the same or similar investment objective are
made pro rata based upon account size. There is no allocation to an account or set of
accounts based on account performance or the amount or structure of management fees.
When such concurrent authorizations occur, the objective will be to allocate the executions
in a manner that is deemed equitable to the accounts involved. However, the following
factors may justify an allocation that deviates from the general rule.
(1) Specific allocations may be chosen in order to adjust or maintain the overall ratios
of specific securities held by client accounts.
(2) Specific allocations may be chosen based upon an account's existing positions in
securities.
(3) Specific allocations may be chosen because of the cash availability of one or more
particular accounts.
(4) Specific allocations may be chosen for tax reasons.
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(5) An account’s allocation may be eliminated, reduced, or increased because of
investment policies and restrictions, account guideline limitations, or investment
objectives. Clients with specific investment policies, restrictions, or limitations may
not be able to participate in certain aggregated transactions and therefore may not
benefit from average pricing.
The overarching principle for that allocation is that no client is intentionally favored over
another client that is similarly situated. Schwab does not provide a commission break to
aggregated trades.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and
Advisory Persons Involved
Account reviews are performed quarterly by the Chief Compliance Officer of S4W. Account
reviews are performed more frequently when market conditions dictate. Reviews of Client
accounts include, but are not limited to, a review of Client documented risk tolerance,
adherence to account objectives, investment time horizon, and suitability criteria, reviewing
target bans of each asset class to identify if there is an opportunity for rebalancing, and
reviewing accounts for tax loss harvesting opportunities.
Financial plans generated are updated as requested by the Client and pursuant to a new or
amended agreement, S4W suggests updating at least annually.
Review of Client Accounts on Non-Periodic Basis
Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws,
new investment information, and changes in a Client's own situation.
Content of Client Provided Reports and Frequency
Clients receive written account statements no less than quarterly for managed accounts.
Account statements are issued by S4W’s custodian. Client receives confirmations of each
transaction in their account from the Custodian and an additional statement during any
month in which a transaction occurs.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External Sources and
Conflicts of Interest
The Firm does not pay outside individuals or entities for referring clients.
Advisory Firm Payments for Client Referrals
S4W does not compensate for Client referrals.
Item 15: Custody
Account Statements
All assets are held by qualified custodians, which means the custodians provide account
statements directly to Clients at their address of record at least quarterly. Clients are urged
to compare the account statements received directly from their custodians to any
documentation or reports prepared by S4W.
S4W is deemed to have constructive custody solely because advisory fees are directly
deducted from Client’s accounts by the custodian on behalf of S4W.
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For private fund investments, an independent public accountant will annually audit the
pooled investment vehicle(s) that we manage. Audited financial statements are annually
distributed to the Fund investors.
Item 16: Investment Discretion
Discretionary Authority for Trading
Client will authorize S4W discretionary authority, via the Investment Advisory Agreement,
to determine, without obtaining specific Client consent, the securities to be bought or sold,
and the amount of the securities to be bought or sold. If applicable, Client will authorize
S4W discretionary authority to execute selected investment program transactions as stated
within the Investment Advisory Agreement. If, however, consent for discretion is not given,
S4W will obtain prior Client approval before executing each transaction.
S4W allows Clients to place certain restrictions, as outlined in the Client’s Investment Policy
Statement or similar document. Such restrictions could include only allowing purchases of
socially conscious investments. These restrictions must be provided to S4W in writing.
Item 17: Voting Client Securities
Proxy Votes
The Firm does not vote proxies for securities held in clients’ accounts. Clients receive proxy
material directly from their account custodian by either email or U.S. mail. Clients may
address questions concerning a proxy matter to Firm personnel.
Item 18: Financial Information
Balance Sheet
Except for private fund investments, a balance sheet is not required to be provided
because S4W does not serve as a custodian for Client funds or securities and S4W does
not require prepayment of fees of more than $1,200 per Client and six months or more in
advance.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to
Meet Commitments to Clients
S4W has no condition that is reasonably likely to impair our ability to meet contractual
commitments to our Clients.
Bankruptcy Petitions during the Past Ten Years
S4W has not had any bankruptcy petitions.
Item 19: Requirements for State Registered Advisors
Principal Executive Officers and Management Persons
S4W is an SEC-registered investment adviser; so, this section is not applicable.
Item 2 Educational Background and Business Experience
S4W is an SEC-registered investment adviser; so, this section is not applicable.
Outside Business Activities
S4W is an SEC-registered investment adviser; so, this section is not applicable.
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Performance Based Fee Description
S4W is an SEC-registered investment adviser; so, this section is not applicable.
Disclosure of Material Facts Related to Arbitration or Disciplinary Actions
Involving Management Persons
S4W is an SEC-registered investment adviser; so, this section is not applicable.
Material Relationship Maintained by this Advisory Business or Management
persons with Issuers of Securities
S4W is an SEC-registered investment adviser; so, this section is not applicable.
Material Conflicts of Interest Assurance
S4W is an SEC-registered investment adviser; so, this section is not applicable.
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