TEAM HEWINS, LLC

ITEM 1: COVER PAGE TEAM HEWINS, LLC Firm Brochure (Part 2A of Form ADV) February 24, 2026 Contact: Michelle McCarthy, Chief Compliance Officer 950 Tower Lane, Suite 1050 Foster City, CA 94404 Phone: 513-832-5447 Fax: 650-372-0813 www.teamhewins.com This Brochure provides information about the qualifications and business practices of Team Hewins, LLC (“Team Hewins”). If you have any questions about the contents of this Brochure, please contact us at 650- 620-3040. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“the SEC”) or by any state securities authority. Team Hewins is registered as an investment advisor with the SEC. Registration of an investment adviser does not imply any level of skill or training. Additional information about Team Hewins is also available on the SEC’s website at www.adviserinfo.sec.gov. Team Hewins, LLC – Part 2A of Form ADV Page 1  ITEM 2: MATERIAL CHANGES Team Hewins is required to make clients aware of information that has changed since the last annual update to the Firm Brochure (“Brochure”) and that may be important to them. Clients can then determine whether to review the brochure in its entirety or to contact us with questions about the changes. The last annual update of our Firm Brochure occurred on February 26, 2025. As part of this annual update, this Brochure was revised to reflect the following material changes: In January 2026, Cover Page updated to reflect our new main office location in Foster City, California Team Hewins, LLC – Part 2A of Form ADV Page 2  ITEM 3: TABLE OF CONTENTS COVER PAGE Item 1: 1 Item 2: MATERIAL CHANGES 2 ADVISORY BUSINESS Item 4: 4 FEES AND COMPENSATION Item 5: 10 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Item 6: 14 TYPES OF CLIENTS Item 7: 14 Item 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS 14 Item 9: DISCIPLINARY INFORMATION 20 Item 10: OTHER FINANCIAL ACTIVITIES AND AFFILIATIONS 20 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND Item 11: PERSONAL TRADING 20 Item 12: BROKERAGE PRACTICES 21 Item 13: REVIEW OF ACCOUNTS 24 Item 14: CLIENT REFERRALS AND OTHER COMPENSATION 25 Item 15: CUSTODY 25 Item 17: VOTING CLIENT SECURITIES & SECURITIES CLASS ACTION POLICY 27 FINANCIAL INFORMATION Item 18: 29 Team Hewins, LLC – Part 2A of Form ADV Page 3  ITEM 4: ADVISORY BUSINESS Team Hewins, LLC (“Team Hewins,” “the Firm,” “we,” “our” or “us”) is a limited liability company formed in 2017 in the state of Delaware. The SEC granted Team Hewins’ registration as an investment advisor effective April 20, 2018. Team Hewins is owned by Roger Hewins (who has the largest interest), John Bussel (who has the next largest interest), Mikhael Balachov (who has the next largest interest after John Bussel) and several other members. Eight principals of Team Hewins were previously principals with Hewins Financial Advisors, LLC (founded on October 1, 1999), which was affiliated with the CPA firm, Wipfli LLP, and was wholly owned by Wipfli Financial, LLC (collectively, “Wipfli”). Effective May 31, 2018, these Team Hewins principals redeemed their membership interests in Wipfli. Other personnel (non- members) also joined the Team Hewins team, which launched on June 1, 2018 with four offices and $1.86B in Assets Under Management. Mr. Balachov manages day-to-day operations of the Firm with assistance from the Firm’s senior management team, which meets weekly. The Firm established the Board of Managers in late 2023 with three principals on the Board and the Board represents the interest of the principals. For additional information about Team Hewins’ ownership structure, please refer to Schedule A of our Form ADV Part 1A, which is available at no cost either online at www.sec.gov or by contacting the Firm itself. As discussed below, Team Hewins offers investment advisory and financial planning services to our clients (including individuals and couples, families, business entities, pension and profit-sharing plans, trusts, estates, and charitable organizations). Clients are free to choose one service without any obligation to engage us for any other. We reserve the right to refuse any engagement we deem as an improper fit for our services. A. INVESTMENT ADVISORY SERVICES In addition to our financial planning and investment advisory services, we also provide Retirement Plan Services and other consulting services. Each of our services is described below, and fees for each service are discussed in Item 5. 1. Standard Investment Advisory Services Our standard investment advisory services are available to individuals and families, trusts and estates, pension and profit-sharing plans, business entities and charitable organizations. Clients can engage us to provide ongoing investment advisory services on a discretionary or non-discretionary basis in accordance with the client’s investment objectives. Our services and all conditions to them are fully described in the written Investment Advisory Agreement, provided to, and signed by each client. Our minimum account size (i.e., a required minimum amount of assets under our management (“AUM”)) for standard investment advisory services is $250,000. We may waive the minimum account size depending on client circumstances. Team Hewins, LLC – Part 2A of Form ADV Page 4  We provide investment advisory services specific to the needs of each client. These services are provided to the client by a dedicated Team Hewins Investment Advisor Representative (“IAR”) or team of IARs. The IAR ascertains, in consultation with the client, the client’s financial situation, risk tolerance and investment objectives as well as other pertinent information. From this information, the IAR prepares a written Investment Policy Statement (“IPS”) that is then reviewed and signed by the client. The IPS can be modified at any time after a consultation between the client and the IAR. We generally recommend that clients allocate their investment assets among various mutual funds and Exchange Traded Funds (ETFs); however, depending on the client’s specific financial situation, objectives, and risk tolerances, we sometimes recommend Independent Third-Party Asset Managers or Private Investment Funds where appropriate and as described below. All recommendations are made in accordance with the investment profile of the client and investment strategies set forth in the IPS. In certain circumstances, clients are permitted to impose reasonable restrictions regarding their investments — for example, through “socially responsible” investing. As part of our investment advisory services, we make certain investment benefits available to our clients that are not otherwise available to retail investors. Such benefits include: • Access to professionally developed and monitored model portfolios suitable for investors with a wide range of risk tolerances; • Access to institutional share classes (i.e., lower-cost share classes) of certain mutual fund families, by virtue of our business relationship with those fund families; • Access to certain fund families whose substantial minimums would normally preclude retail client investment. We are able to offer funds from these fund families due to the level of assets that we invest on behalf of our clients; and • Access to certain lower-cost mutual fund families made available only to a select group of registered investment advisors. Clients are strongly encouraged to communicate to us any changes to their financial circumstances or any other material changes in their lives that could impact their investments. As described in Item 8, portfolio rebalancing and tax-loss harvesting are part of the standard investment advisory services we provide for clients. Although clients can engage us for financial planning services alone (as discussed in greater detail below), we generally provide financial planning services in conjunction with our standard investment advisory services. We use an interactive planning tool to develop a thorough understanding of our clients and their financial lives. The use of this tool provides clients with immediate visual feedback of the financial results stemming from different assumptions and choices. This information is used to help clients establish investment objectives and risk tolerances. In general, our clients’ accounts are implemented via the custody platform at Schwab Advisor Services, a division of Charles Schwab & Co., Inc. (hereinafter referred to as “Schwab”). To receive our services, clients enter into written account agreements with the custodian. For fees associated with custodial services, please refer to Item 5. Team Hewins, LLC – Part 2A of Form ADV Page 5  a. Independent Managers Team Hewins may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets to one or more unaffiliated independent investment managers in accordance with the client’s designated investment objective(s). Factors that we consider before recommending an independent manager include but are not limited to the client’s investment objectives, the overall size of the client’s investment portfolio, and the independent manager’s management style, investment team, performance history, reputation, financial strength, pricing, and investment process. Some of these independent managers are not available to the general public. The independent manager shall have day-to-day responsibility for the discretionary management of the allocated assets, and we will continue to render investment advisory services regarding the assets placed with the independent manager, including the ongoing monitoring and review of account performance and compliance with the client’s investment objectives. If a client chooses to invest with independent managers, he or she will incur a separate fee for the independent manager for those services, and the value of the client’s assets invested with the manager will be included in the calculation of our investment advisory fees. We do not receive any referral fees for recommending any independent manager. b. Private Investment Funds We provide some of our high-net-worth clients with investment advice regarding private investment funds. Our role relative to private investment funds shall be limited to initial and ongoing due diligence and investment monitoring services. If a client chooses to become a private investment fund investor, the client will enter into a separate agreement with the private investment fund(s) in question and will incur separate fees that vary based upon the specifics of the fund(s). Assets invested in the private investment fund(s) will be included in the calculation of our investment advisory fees. We do not receive any referral fee for recommending any investment with a private investment fund. The Firm’s principals and employees might invest in private investment funds that have been recommended to or are owned by certain clients. Our private fund investment program is recommended only to clients that meet certain investor sophistication standards that are defined in the federal securities laws and regulations, i.e. accredited investor standard or qualified purchaser standard. Each fund will have a sophistication standard that a client must meet, as set forth in the fund’s governing documents. Given the illiquid and risky nature of private equity investing, clients who decide to invest in these funds must be willing to commit to a long- term investment and tolerate the high risk associated with investing in them. Additionally, many private investment funds have high minimum investment amounts (typically between $250,000 and $500,000); therefore, we recommend them to clients that have a level of assets that enables them to achieve appropriate diversification (by investment type and vintage year) within this segment. Risks that are specific to investing in private investment funds are discussed in detail, among all other risks, in Item 8 of this Brochure. Team Hewins, LLC – Part 2A of Form ADV Page 6  2. Retirement Plan Services – Investment Advisory Services for Employee Benefit Plans We provide investment advisory services to employee benefit plans, including but not limited to 401(k) plans, profit-sharing plans, and pension plans. Each employee benefit plan client (“Plan”) that engages us for Retirement Plan Services can generally do so either on an ERISA Section 3(38) fiduciary basis or an ERISA Section 3(21) fiduciary basis. When a Plan engages us for either ERISA 3(21) basis or ERISA 3(38) basis, we acknowledge our status as a fiduciary to the Plan, as defined in Sections 3(38) and 3(21) of ERISA, and we assume the duties, responsibilities, and obligations of such a fiduciary. Furthermore, Team Hewins acknowledges that it adheres to impartial conduct standards, whereby we provide investment advice that is in the best interest of the Plan; we receive compensation that is not in excess of reasonable compensation (within the meaning of ERISA); and we will not make any materially misleading statements to the Plan regarding the advisor’s services and recommendations, fees and compensations, material conflicts of interest and any other matters relevant to the Plan’s investment decisions. The exact scope of our services varies depending on whether we are engaged on an ERISA 3(38) fiduciary basis or an ERISA 3(21) fiduciary basis. We reserve the right to refuse to be engaged on an ERISA 3(38) basis or an ERISA 3(21) basis, or for any particular type of Retirement Plan Services, in any particular engagement. As part of our Retirement Plan Services, we provide the following services to the Plan: • We review the Plan’s investment policies and guidelines with the Plan’s sponsor; • We work with the Plan sponsor to develop an IPS for the Plan; • In accordance with the investment strategies in the Plan’s IPS, we help design, implement, and monitor investment options for the Plan’s participants; • We report to and meet with the Plan’s sponsor(s) on a regular basis to review performance of the Plan’s investment options and participant participation; • Depending upon the scope of the arrangement with the Plan, we provide periodic on-site enrollment meetings with the Plan’s participants; and • We provide education to the Plan’s participants regarding the benefits of participating in the Plan and answer participants’ questions regarding the Plan’s investment options, both remotely and on-site periodically. Typically, a Plan that engages us on an ERISA 3(38) basis for Retirement Plan Services does so on a discretionary basis, while a Plan that engages us on an ERISA 3(21) basis does so on a non-discretionary basis. Our minimum account size (i.e., a required minimum amount of assets under our management (“AUM”)) for Retirement Plan Services is $1,000,000. We may waive the minimum account size depending on client circumstances. Details regarding our fees for Retirement Plan Services are discussed in detail in Item 5 of this Brochure. Team Hewins, LLC – Part 2A of Form ADV Page 7  B. OTHER SERVICES 1. Financial Planning and Consulting Services Clients who do not have an investment advisory relationship with us can elect to receive financial planning services pursuant to the terms of a written Financial Planning Agreement. The Financial Planning Agreement describes the scope of the services to be provided and the fees to be charged. We can, in our sole discretion, waive any or all fees for these services. Neither we, nor any of our employees, serve our clients as an accountant or attorney, and no portion of our services should be viewed as a substitute for such services. C. ADDITIONAL OBLIGATIONS AND DISCLOSURES REGARDING OUR SERVICES 1. Client Obligations and Responsibilities We offer our clients a selection of services; clients who engage us for one of the services we provide are under no obligation to engage us for any of the other services. We are not required to verify any information we receive from the client or from the client’s other professionals, and the Investment Advisory Agreement expressly authorizes us to rely on information provided to us. It remains the client’s responsibility to promptly notify us if there is ever any change to his or her financial situation or investment objectives so that our recommendations continue to be appropriate for their needs. 2. Courtesy (Non-Managed) Accounts As a matter of accommodation and convenience to existing Team Hewins clients who have other managed assets with us, we allow clients to establish Courtesy Accounts (“Courtesy Accounts”) at Schwab wherein they receive the benefit of Team Hewins’ negotiated pricing and share classes associated with non-retail accounts. Such Courtesy Accounts can only be established after the client signs a Courtesy Account Agreement. Team Hewins does not assume the responsibility to manage, monitor, or report on these accounts, or any securities that they may hold. Clients are strongly encouraged to effectuate their own trading in these Courtesy Accounts. Team Hewins makes the best effort to accommodate non-solicited trade requests from clients, but only upon clients’ explicit written instructions, and only after review and approval by Team Hewins’ Chief Operating Officer or Director of Operations. Team Hewins cannot guarantee timely execution of any such trades and reserves the right to reject any trade. Clients who wish to establish a Courtesy Account should review the Courtesy Account Agreement carefully prior to signing it. Team Hewins will not charge any fees on Courtesy Accounts. Wrap Fee Program 3. We do not participate in a wrap fee program. Team Hewins, LLC – Part 2A of Form ADV Page 8  Assets Under Management 4. As of December 31, 2025, Team Hewins had total regulatory assets under management (“RAUM”) of $3,966,070,638 of which $1,989,508,914 was managed on a discretionary basis and $1,976,561,724 was managed on a non-discretionary basis. 5. Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Team Hewins recommends that a client roll over their retirement plan assets into an account to be managed by Team Hewins, such a recommendation creates a conflict of interest if Team Hewins will earn new (or increase its current) compensation as a result of the rollover. If Team Hewins provides a recommendation as to whether a client should engage in a rollover or not, Team Hewins is acting as 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. No client is under any obligation to roll over retirement plan assets to an account managed by Team Hewins. Team Hewins’ Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Fiduciary Status: Per the Department of Labor (DOL), when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are 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. The way we are compensated may create some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Accordingly, relative to retirement accounts, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. 6. Asset Management Services through Pontera When appropriate, we use a third-party platform to facilitate management of held-away assets, with discretion, and may leverage an Order Management System to implement tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. These are primarily defined contribution plan Team Hewins, LLC – Part 2A of Form ADV Page 9  participant accounts, 401(k) accounts, HSAs, and other assets. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client login credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Team Hewins will review the current account allocations. When deemed necessary, Team Hewins will rebalance the account considering client investment goals and risk tolerance. The securities utilized by Team Hewins for investment in these particular client accounts are typically limited to the available account options, over which Team Hewins has no control. Client account(s) will be reviewed at least quarterly, and allocation changes will be made as deemed necessary. ITEM 5: FEES AND COMPENSATION A. INVESTMENT ADVISORY SERVICES Our fees for our investment advisory service lines (Standard Investment Advisory Services and Retirement Plan Services) are set forth immediately below. In each instance, our annual fees for investment advisory services are paid quarterly in advance, based upon the market value of the AUM on the last business day of the previous quarter. We may aggregate clients’ assets with assets of their family members, who are also our clients, to allow all members of the family to achieve fee breakpoints. The initial quarterly fee is based on funding date(s) or the date(s) assets are transferred. Generally, clients elect to have our advisory fees deducted from their custodial accounts. The custodial agreement signed by the client typically authorizes the custodian to debit the account for the amount of our fees and to directly remit the fees to us in compliance with procedures accepted by the SEC. For a small subset of clients for whom direct billing is necessary, payment is due upon receipt of our invoice. Our Investment Advisory Agreements with our clients continue in effect until terminated by either the client(s) or us with 30 days written notice. Depending on circumstances, we may waive the notice requirement. After termination, we will provide a prorated refund on any unearned portion of the advisory fee that was paid in advance, in accordance with the terms of the Investment Advisory Agreement. Any refund due will be paid within five weeks of notice of termination. 1. Standard Investment Advisory Services Our annual fee for standard investment advisory services is tiered, based upon a percentage (%) of the market value of the AUM as follows: Team Hewins, LLC – Part 2A of Form ADV Page 10  ASSET BREAKPOINTS ANNUAL FEE First $2,000,000 1.00% Next $3,000,000 0.85% Next $5,000,000 0.40% Above $10,000,000 0.30% We may negotiate discounts from the above quoted fees. Any fee discounts must be approved by a member of our senior management and documented. The fees above are for standard investment advisory services, as detailed in each applicable Investment Advisory Agreement, and include basic financial planning services. If a client requires specific consulting services, those services may require a separate agreement and incur a separate fee. Team Hewins typically charges a minimum fee of $625 per quarter but reserves the right to waive the minimum fee on a case-by-case basis. Although Team Hewins believes that its fees are competitive, clients should understand that lower fees for comparable services may be available from other sources and firms. Independent Managers and Private Investment Funds Independent manager and private investment fund fees are in addition to and separate from the advisory fees we charge. Fees charged will vary among the independent managers and private investment funds. The independent manager’s fee will be outlined in the agreement between the independent manager and Team Hewins or the agreement between the independent manager/private fund and the client. The fee for private investment funds will be outlined in the offering documents provided by the fund. 2. Retirement Plan Services The annual fee for Retirement Plan Services, regardless of whether we are engaged as an ERISA 3(38) fiduciary or a 3(21) fiduciary, is tiered and based on a percentage (%) of the market value of the assets of the Plan under management, as follows: Team Hewins, LLC – Part 2A of Form ADV Page 11  ASSET BREAKPOINTS ANNUAL FEE First $500,000 0.75% Next $1,500,000 0.50% Next $3,000,000 0.40% Next $5,000,000 0.25% Next $5,000,000 0.20% Above $15,000,000 0.10% We may negotiate discounts from the above quoted fees. Any fee discounts must be approved by a member of our senior management and documented. Team Hewins typically charges a minimum fee of $625 per quarter but reserves the right to waive the minimum fee on a case-by-case basis. B. OTHER SERVICES 1. Financial Planning and Consulting Services Our financial planning and consulting fees are negotiable and dependent upon the level and scope of the services required as well as the IAR(s) rendering the services. Fees typically range from $3,000 to $10,000 on a fixed-fee annual basis, or $350 to $400 per hour on an hourly rate basis. Fees for financial planning and consulting services are typically billed either on a quarterly or monthly basis or at the end of the project, except in cases of projects with extended length, where interim billing could take place. These fees are not deducted from client accounts; instead, they are paid directly by the client. We reserve the right to request an initial deposit. C. OTHER FEES Below is a description of some, but possibly not all, of the fees clients are expected to pay to third parties, in addition to our fees but in relation to the services we perform. 1. Custodial Fees We generally recommend that Schwab serve as the custodian for our clients’ advisory assets. Fees charged by the custodian are separate from and in addition to the fees clients pay to us. There are two different arrangements for custodial fees at Schwab: Asset-Based Pricing (“ABP”) and Transaction-Based Pricing (“TBP”). The ABP method assesses fees based on the value of the portfolio, rather than on individual transactions, and TBP charges a fee, if applicable, per each trade placed in the Team Hewins, LLC – Part 2A of Form ADV Page 12  account. Team Hewins recommends ABP or TBP custodial pricing for our clients after conducting a thorough analysis of each specific client’s portfolio. Among factors analyzed are the account size, the number of withdrawals and contributions anticipated from the account per year, and other account- specific factors. The fees charged by the custodian are set forth by Schwab and are subject to change. While Team Hewins negotiates these fees from time to time with the custodian to benefit our clients, there is no guarantee that we will be able to negotiate any specific fees or fee ranges. Schwab’s custodial fees can be higher or lower than those charged by other custodians. For clients using other custodians, fees will vary according to the custodian selected. For further information on our custody/brokerage practices, see Item 12. 2. Mutual Fund and ETF Fees Mutual fund and ETF fees are in addition to and separate from the advisory fee we charge. All mutual funds and ETFs have an internal expense ratio, which is the annual percentage of the funds’ assets that the fund managers (not Team Hewins or the account custodian) charge to manage the funds. When selecting funds for our model portfolios, we focus on funds with low expense ratios. Team Hewins also selects funds or specific share classes that do not charge “12b-1 fees” (marketing/distribution fees) or “loads” (sales charges assessed on the amount that the client invests into the fund). Furthermore, whenever possible, Team Hewins strives to select institutional share classes of those mutual funds that we recommend to clients. Institutional shares do not charge any loads and tend to have significantly lower expense ratios. The custodian will provide each client with a fund prospectus for each mutual fund or ETF in which the client invests. The prospectus discloses, among other important information, the mutual fund’s or ETF’s management and fee structure. We do not provide the prospectus; however, clients are strongly encouraged to review prospectuses and to speak with their Team Hewins IAR in case there are any questions, specifically about mutual fund or ETF fees. 3. Fees for Held-Away Assets Investment management fees are generally directly debited quarterly in advance, based upon the market value of the AUM on the last business day of the previous quarter. The exception for this is directly- managed held-away accounts, such as 401(k)s. As it is impossible to directly debit the fees from these accounts, those fees will be assigned to the client’s managed accounts or be collected in another way that is mutually agreed upon by Team Hewins and the client. 4. Fees for Other Services Fees for other related services range widely and depend on the complexity and scope of the services to be rendered. Fees will be negotiated in advance and documented as an addendum to the client’s Investment Advisory Agreement, to be agreed to in writing by both Team Hewins and the client. Where applicable, we will pay appropriate third parties any share of these fees that have been earned in conjunction with Team Hewins, LLC – Part 2A of Form ADV Page 13  rendering other services to our clients. We will not receive any financial benefit from these third parties as a result of the performance of these services. D. WAIVER OF FEE FOR EMPLOYEE ACCOUNTS As an added benefit that is available only to Team Hewins’ employees, principals, and immediate members of their families — which include spouses and children under age 21 (collectively, “Employees”) — Team Hewins will allow Employees to open accounts for their own benefit at Schwab, and Team Hewins will invest these accounts into one of Team Hewins’ model portfolios. This benefit is provided to Employees at no cost, but Employees bear all costs associated with trading and holding the funds in the accounts. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE ITEM 6: MANAGEMENT Neither Team Hewins, nor any of our supervised persons, accept performance-based fees. We do not engage in side-by-side management. ITEM 7: TYPES OF CLIENTS Our clients include individuals and families, business entities, pension and profit-sharing plans, trusts, estates, and charitable organizations. Our minimum account size is generally $250,000 for standard investment advisory services and $1,000,000 for retirement plan services. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS A. BASIC STRATEGY The foundation of our investment philosophy is to be highly disciplined, mitigate risks through asset class diversification and invest for the long term. Our Investment Committee (the “IC”) is responsible for the research and due diligence that goes into our asset allocation approach, fund recommendations and portfolio monitoring. The IC develops model portfolios based on Modern Portfolio Theory (“MPT”). The primary focus of MPT is to make investment decisions based on stated objectives and risk, evaluate investment performance at the portfolio level, minimize risks attributable to specific securities through broad diversification, and hold assets that are not highly correlated. MPT tells us that a portfolio can be constructed by combining asset classes in an optimal way so as to produce the highest return for a stated level of risk. Regardless of the amount a specific client has to invest, we help him or her determine an appropriate asset allocation, given their objectives and risk tolerance. We then implement that allocation in a broadly Team Hewins, LLC – Part 2A of Form ADV Page 14  diversified portfolio. Depending on the size of the client’s investment portfolio, among other factors, we may use mutual funds, ETFs, separately managed accounts with independent managers, and other vehicles, including private investment funds, if appropriate. Interim fluctuations in market value and rates of return may be experienced in order to achieve long-term objectives. We employ no tactical or market-timing elements within our overall strategy. However, individual funds and managers that we recommend, or those used by the client, may employ different strategies with different associated risks at times. There is a risk of loss, described in more detailed below, that clients should be prepared to bear. B. INVESTMENT STRATEGY RELATIONSHIP Callan 1. To augment our base of financial- and investment-related information and for the purposes of additional sophisticated analysis, we have engaged Callan. Callan is one of the largest investment consulting firms in the country, and provides research, education, decision-making support, and advice to a broad array of institutional investors. We are a member of the Callan Independent Adviser Group (“IAG”), an organization of approximately 25 registered investment advisor firms. Through our membership in Callan’s IAG, we have access to resources normally only available to the largest investors, including: • Capital market projections related to risk, return and correlations of asset classes; • Asset allocation software; • A select list of recommended investment management organizations and products (in the form of mutual fund, ETF, and separate account vehicles), based on in-depth qualitative and quantitative due diligence. Many of these money managers provide their services to IAG member clients at reduced minimums and discounted fees; • A comprehensive database of mutual funds, ETFs, and separate account managers; and • Research on various investment topics. C. CAPITAL MARKET EXPECTATIONS In determining an appropriate asset allocation for a client, we perform an asset allocation analysis based on long-term, forward-looking capital markets expectations and correlations among the various asset classes. These expectations are imprecise by nature; it is not possible to predict future performance. There can be no assurance that future returns will approximate the long-term historical rates of return for each asset class or that future performance of an asset mix will fall within the range of returns produced by such an analysis. Team Hewins, LLC – Part 2A of Form ADV Page 15  D. REBALANCING AND TAX-LOSS HARVESTING Based upon the client’s prior written agreement to do so, we have, without further approval, the authorization to rebalance the client’s portfolio and perform tax-loss harvesting in accordance with the client’s approved asset allocation. Over time, the value of different asset and sub-asset classes of a client’s portfolio can rise or fall so that their percentages fall outside the asset allocation range defined in the client’s IPS. We periodically review client accounts to determine if rebalancing is advisable and, if so, reallocate the account in accordance with the client-approved strategic asset allocations. Cash inflows/outflows are deployed in a manner consistent with a client’s strategic asset allocation. Tax-loss harvesting is the process of selling selected securities at a loss to help offset capital-gains tax liabilities. To take advantage of such tax losses, our Investment Advisory Agreements state that we may, without further client approval, sell investments and replace those investments with other investments within the same asset class. In general, after the required time lapse, we will return the client’s investments back to the original investments if it is advisable from a tax perspective. E. INVESTMENT RISK The following is an outline of the main risks pertaining to the asset classes utilized by Team Hewins: • Market Risk: The price of a security can drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. • Equity Risk: Historically, the equity markets have moved in cycles, and the value of equity securities can fluctuate significantly from day to day. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments. The prices of securities issued by such companies can suffer a decline in response. These factors contribute to price volatility. • Business Risk: This risk is associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it — a lengthy process — before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. • Foreign Risk: Investments in foreign securities pose special risks — including currency fluctuation and political risks — and such investments can be more volatile than that of a United States-only investment. The risks are generally greater for investments in emerging markets. • Currency Risk: Foreign 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.” Team Hewins, LLC – Part 2A of Form ADV Page 16  • Political and Legislative Risk: Companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, bringing significant impact, especially for companies operating outside of the United States or those companies who conduct a substantial amount of their business outside of the United States. • Force Majeure Risk: This a risk that securities and markets may be adversely impacted by international hostilities, terrorist activities, natural disasters, pandemics, or other unexpected infrastructure disruptions. of Environmental, Social and Governance (ESG) considerations into indices. Investors must accept these limitations, including potential • Socially Responsible Investing Risk/Limitations: Socially Responsible Investing involves the the incorporation investment due diligence process. There are potential limitations associated with allocating a portion of an investment portfolio to ESG securities or funds (e.g., funds that have a mandate to avoid, when possible, investments in businesses associated with alcohol, tobacco, firearms, oil drilling, gambling, etc.). The number of these securities/funds may be limited when compared to those that do not maintain such a mandate. ESG securities/funds could underperform broad market for underperformance. The number of ESG mutual funds and exchange traded funds are few when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Registrant), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. • Fixed Income – Credit Risk: This is the risk that principal and/or interest on a fixed-income investment will not be paid in a timely manner or in full, due to changes in the financial condition of the issuer. Generally, the higher the perceived credit risk, the higher the rate of interest investors will receive on their investment. Many bonds are rated by a third-party Nationally Recognized Statistical Rating Organization (“NRSRO”) — for example, Moody’s Investor Services or Standard & Poor’s Inc. While ratings may assist investors in determining the creditworthiness of the issuer, they are not a guarantee of performance. Treasury bills, notes and bonds are guaranteed by the full faith and credit of the United States, and therefore are deemed to carry no risk of default. • Fixed Income – Interest Rate Risk: This is the risk that the value of an interest-bearing investment will change, due to changes in the general level of interest rates in the market. The market value of a bond fluctuates inversely to the change in interest rates; that is, as interest rates rise, bond prices fall and vice versa. Interest rate risk is commonly measured by a bond’s duration; the greater a bond’s duration, the greater the impact on its price due to a change in interest rates. Investors can incur a gain or loss from bonds sold prior to the final maturity date. • Fixed Income – Municipal Securities Risk: To the extent an account is invested in bonds issued by local governments, such bonds are subject to the fixed income risks described above as well as additional risks which are: Team Hewins, LLC – Part 2A of Form ADV Page 17   Legislative Risk: The risk that change in legislation (e.g., changes in the tax code) will have an effect on the value of tax-exempt interest income;  Liquidity Risk: The risk that investors are not able to find a buyer when they want to sell and could be forced to sell their holdings at a significant discount. Liquidity risk is greater for bonds with lower ratings, bonds that are part of a small issue, recently downgraded bonds or bonds by an issuer who issues infrequently. • Liquidity Risk: The risk stemming from the lack of marketability of an investment that cannot be bought or sold quickly enough to prevent or minimize a loss. Liquidity risk is typically reflected in a wide bid-ask spread or large price movements. It is also a risk associated with an investment in private funds. • Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. • Opportunity Cost Risk: The risk that an investor can forego profits or returns from other investments. • Financial Risk: Excessive borrowing to finance a business’s operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. • Mutual Fund Risk: An investment in a mutual fund involves risk, including the loss of principal. Mutual fund shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level realized capital gains, interest and dividends as mutual funds are required by law to distribute them. As such, a mutual fund investor may incur substantial tax liabilities even when the fund underperforms. • Risks for Investing in Non-Liquid Alternative Investments: From time to time, Team Hewins will recommend to certain qualifying clients that a portion of such client’s assets be invested in private investment funds, private investment fund-of-funds and/or other alternative investments (collectively, “Non-Liquid Alternative Investments”). Non-Liquid Alternative Investments are not suitable for all Team Hewins’ clients and are offered only to those qualifying clients for whom Team Hewins believes such an investment is suitable and in line with their overall investment strategy. Non-Liquid Alternative Investments typically are available to only a limited number of sophisticated investors who meet the definition of “accredited investor” under Regulation D of the Securities Act of 1933, as amended (the “Securities Act”), or “qualified client” under the Investment Advisers Act of 1940, or “qualified purchaser” under the Investment Company Act of 1940. Non-Liquid Alternative Investments present special risks for Team Hewins’ clients, including without limitation, limited liquidity, higher fees and expenses, volatile performance, no assurance of investment returns, heightened risk of loss, limited transparency, additional reliance on underlying management of the investment, special tax considerations, subjective Team Hewins, LLC – Part 2A of Form ADV Page 18  valuations, use of leverage, and limited regulatory oversight. When a Non-Liquid Alternative Investment invests part or all of its assets in real estate properties, there are additional risks that are unique to real estate investing, including but not limited to: limitations of the appraisal value; the borrower’s financial conditions (if the underlying property has been obtained by a loan), including the risk of foreclosures on the property; neighborhood values; the supply of and demand for properties of like kind; and certain city, state and/or federal regulations. Additionally, real estate investing is also subject to possible loss due to uninsured losses from natural and man- made disasters. The above list is not exhaustive of all risks relating to an investment in Non-Liquid Alternative Investments. A more comprehensive discussion of the risks associated with a particular Non- Liquid Investment is set forth in that fund’s offering documents, which will be provided to each client subscribing to a Non-Liquid Alternative Investment, for review and consideration. It is important that each potential, qualified investor carefully read each offering or private placement memorandum prior to investing. telecommunications failures, • Cybersecurity Risk: Team Hewins and its service providers are subject to risks associated with a breach in cybersecurity. Cybersecurity is a generic term used to describe the technology, processes and practices designed to protect networks, systems, computers, programs and data from both intentional cyber-attacks and hacking by other computer users as well as unintentional damage or interruption that, in either case, can result in damage or interruption from computer viruses, network failures, computer and infiltration by unauthorized persons and security breaches, usage errors by their respective professionals, power outages and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. A cybersecurity breach could expose Team Hewins to substantial costs (including, without limitation, those associated with forensic analysis of the origin and scope of the breach, increased and upgraded cybersecurity, identity theft, unauthorized use of proprietary information, litigation, adverse investor reaction, the dissemination of confidential and proprietary information and reputational damage), civil liability as well as regulatory inquiry and/or action. In addition, any such breach could cause substantial withdrawals from a Team Hewins’ account. While Team Hewins has established a business continuity plan in the event of, and risk management strategies, systems, policies, and procedures to seek to prevent, cybersecurity breaches, there are inherent limitations in such plans, strategies, systems, policies, and procedures including the possibility that certain risks have not been identified. Furthermore, Team Hewins cannot control the cybersecurity plans, strategies, systems, policies, and procedures put in place by other service providers and/or the issuers. Different types of investments involve varying degrees of risk, and no client should assume that future performance of any specific investment or investment strategy (including the investments and/or investment strategies we recommend or undertake) will be profitable or equal to any specific performance levels. All investments represent some level of risk, and an investor should understand that losses can and do occur. Significant losses of invested capital are possible. Moreover, diversification does not protect a portfolio from loss, and it should not be assumed that the broad diversification that is part of our investment strategy is guaranteed to produce profitable results. Individual funds that comprise clients’ portfolios may employ different strategies with different associated risks. Team Hewins, LLC – Part 2A of Form ADV Page 19  If a client’s account has a margin feature, we may, from time to time, use margin for the limited purposes of either raising cash for an immediate disbursement or to facilitate investment changes so that the client remains invested in the market. Occasionally, the client also makes use of the margin feature if more funds are withdrawn than there is cash available. The custodian charges interest on the margined amount at a varying rate, based upon the amount borrowed. The margin feature is generally not available on mutual funds unless the margined securities have been held in the account for at least 30 days. ITEM 9: DISCIPLINARY INFORMATION We have not been the subject of any disciplinary actions. ITEM 10: OTHER FINANCIAL ACTIVITIES AND AFFILIATIONS We are an investment advisor that is registered with the United States Securities and Exchange Commission (“the SEC”). Neither we, nor our representatives, are registered or have applications pending to register as a futures commission merchant, commodity pool operator, a commodity trading advisor or as representatives of the foregoing. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT ITEM 11: TRANSACTIONS, AND PERSONAL TRADING As a fiduciary to its clients, Team Hewins has an ongoing responsibility to ensure that clients’ interests always come first. In doing so Team Hewins must avoid actual and potential conflicts of interest with its clients. To comply with these duties and responsibilities, Team Hewins has adopted a Code of Ethics which serves to establish a standard of business conduct for all of our employees and is based upon fundamental principles of openness, integrity, honesty, and trust. A copy of our Code of Ethics is available at no cost upon request. In accordance with Section 204A of the Investment Advisers Act of 1940, we also maintain and enforce written policies reasonably designed to prevent the misuse of material, nonpublic information by Team Hewins or its employees. These policies are addressed in a formally adopted Insider Trading Policy, which is incorporated in the Code of Ethics. Although our primary investment recommendations are to implement portfolios using mutual funds, ETFs, and Separately Managed Accounts, we require all principals and employees to disclose personal trading accounts to the Firm and report and, in certain instances, preclear all personal trades in reportable securities. Within 10 days of becoming affiliated with Team Hewins, each principal or employee is required to disclose all personal brokerage accounts in which trading in reportable securities takes place or may take place. Prior to buying or selling a reportable security for his/her own benefit, each affiliated person is required to preclear the trade. The Chief Compliance Officer, in collaboration with the Director of Operations or a designee, reviews all preclearance requests for compliance with our Code of Ethics. Team Hewins, LLC – Part 2A of Form ADV Page 20  Affiliated persons who violate the Code of Ethics are subject to disciplinary action up to termination of employment. ITEM 12: BROKERAGE PRACTICES A. THE CUSTODIANS AND BROKERS WE USE Team Hewins does not maintain custody of client assets that we manage, although the Firm is deemed to have custody of client assets if the client gives us authority to withdraw assets from his or her account (see Item 15 of this Brochure). Client assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We usually recommend that our clients use Schwab as qualified custodian. Schwab is a registered broker-dealer and a member of the SIPC. We are independently owned and operated and are not affiliated with Schwab. Schwab will hold client assets in a brokerage account and buy and sell securities when we instruct them to. While we generally recommend that clients use Schwab as custodian/broker, each client will decide whether to do so and will open an account with Schwab by entering into an account agreement directly with them. We do not open the account for clients, although we can assist in doing so. Even though a client account is maintained at Schwab, we can still use other brokers to execute trades for the account, as described below (see “Brokerage and Custody Costs”). B. HOW WE SELECT BROKERS AND CUSTODIANS We seek to use a custodian and/or broker that will hold client 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: • Combination of transaction execution and asset custody services (generally without a separate fee for custody); • Capability to execute, clear and settle trades (buy and sell securities for client accounts); • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, etc.); • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds, etc.); • Availability of investment research and tools that assist us in making investment decisions; • Quality of services and responsiveness of service team; • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices; • Reputation, financial strength, 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 Schwab”); and • Technology platform. Team Hewins, LLC – Part 2A of Form ADV Page 21  C. BROKERAGE AND CUSTODY COSTS For clients whose accounts are maintained by Schwab, custody services are generally not charged separately, but are compensated by either charging clients a commission on applicable trades that are executed or settled into their Schwab account or an asset-based fee on their account. Detailed explanation of these fees and commissions, including the difference between Asset-Based Pricing (“ABP”) and Transaction-Based Pricing (“TBP”), is provided in Item 5 of this Brochure under “Custodial Fees.” Schwab’s TBP (commission) rates and ABP fees applicable to our clients’ accounts were negotiated and are often being renegotiated by Team Hewins to benefit our clients. We have determined that having Schwab execute trades in clients’ accounts is consistent with our duty to seek “best execution” of their trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. D. TRADE AGGREGATION AND ALLOCATION Transactions for each client will be effected independently unless Team Hewins decides to purchase or sell the same securities for several clients at approximately the same time. The Firm can (but is not obligated to) aggregate or “batch” sale and purchase orders with other client accounts that have similar orders being made contemporaneously, if in Team Hewins’ judgment such aggregation is reasonably likely to result in an overall economic benefit to the affected accounts. Such benefits can include better transaction prices and lower trade execution costs. Because of prevailing market conditions, it may not be possible to execute all shares of an aggregated trade, in which case the Firm will allocate the trade among participating accounts in an equitable manner determined prior to execution of the trade. In certain cases, Team Hewins may not be able to purchase or sell the same security for all clients that could transact in the security, which is generally based on various factors such as the type of security, size of the account, cash availability and account restrictions. If such orders cannot be fully executed under prevailing market conditions, Team Hewins can allocate the securities traded among clients and each similar order in a manner which it considers equitable, taking into consideration, among other things, the size of the orders placed, the relative cash positions of each account, the investment objectives of the accounts, and liquidity of the security. E. NON-SOFT DOLLAR RESEARCH AND ADDITIONAL BENEFITS Schwab Advisor Services™ is Schwab’s business that specializes in serving independent investment advisory firms like Team Hewins. Schwab provides us and our clients with access to their institutional brokerage services (trading, custody, reporting and related services), many of which are not typically available to retail customers. Although not a material consideration when determining whether to recommend that a client utilize the services of Schwab, Schwab also makes 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. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. The availability of these services from Schwab benefits us because we do not have to produce or purchase them. The following is a more detailed description of these support services: Services that benefit clients. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that Team Hewins, LLC – Part 2A of Form ADV Page 22  would require a significantly higher minimum initial investment by our clients. The Schwab services described in this paragraph generally benefit clients and their accounts. Services that do not directly benefit clients. Schwab also offers other products and services that benefit us, but do not directly benefit clients or their accounts. These products and services assist us in managing and administering our clients’ accounts; they include investment research, both Schwab’s own and that of third parties. We could use this research to service all or many of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also offers software and other technology that provide us with access to client account data (such as duplicate trade confirmations and account statements); provides access to conference rooms for client meetings; facilitate trade execution; provide pricing and other market data; facilitate payment of our fees from our clients’ accounts; and assist with back-office functions, recordkeeping, and client reporting. Services from Schwab that generally only benefit Team Hewins. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and networking events; • Consulting on technology, compliance, legal and business needs; • Publications and conferences on practice management and business succession; and • Access to various consultants and other service providers. Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Sometimes Schwab also discounts or waive its fees for some of these services or pays all or a portion of a third party’s fees. From time to time, Schwab provides us with other benefits such as occasional business entertainment of our personnel and the use of their facilities for client meetings and occasional Firm events. Ka-Tye Koo, Chief Operating Officer of Team Hewins serves on the Schwab Advisor Services Client Experience Panel (the “CX Panel”). The CX Panel consists of representatives of independent investment advisory firms who have been invited by Schwab to participate in meetings and discussions of Schwab Advisor Services’ services for independent investment advisory firms and their clients. CX Panel members sign non-disclosure agreements with Schwab under which they agree not to disclose confidential information shared with them. This information generally does not include material non-public information about the Charles Schwab Corporation, whose common stock is listed for public trading on the New York Stock Exchange (symbol SCHW). The CX Panel meets in person or virtually approximately twice per year and has periodic conference calls scheduled as needed. CX Panel members are not compensated by Schwab or their participation, but Schwab does pay for or reimburse CX Panel members’ travel, lodging, meals and other incidental expenses incurred in attending meetings. Schwab may also provide members of the CX Panel a fee waiver for attendance at Schwab conferences, such as IMPACT. F. OUR INTEREST IN SCHWAB’S SERVICES Our clients do not pay more for transactions effected and/or assets maintained at Schwab as a result of these services, nor is the availability of these services contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. However, when determining what services to offer to us, Schwab takes into consideration the amount of client assets that we custody with them and trading volumes. We have an incentive to recommend that clients maintain their accounts with Schwab, based on our interest in receiving their services that benefit our business, rather than solely Team Hewins, LLC – Part 2A of Form ADV Page 23  based on clients’ interest in receiving the best value in custody services and the most favorable execution of client transactions. This is a potential conflict of interest. We believe, however, that our selection of Schwab as a custodian and broker, is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab services (see “How We Select Brokers and Custodians”) — not just services that only benefit us. G. DIRECTED BROKERAGE If a client requires that account transactions be placed through a specific broker-dealer, the client will negotiate terms and arrangements for his or her account with that broker-dealer, and we will not seek better execution services or prices from other broker-dealers. As a result, the client could pay higher commissions, other transaction costs or greater spreads, or receive less favorable net prices on transactions for the account than would otherwise be the case. H. TRADE ERRORS If we ever cause a trade error in a client’s account, the client will be made whole. If the correction of the trade error caused by us results in a loss, we are responsible for that loss. If the correction of a trade error by us results in a gain, Schwab will donate the amount of the gain to a charity of Schwab’s choice. I. INITIAL PUBLIC OFFERINGS We do not purchase or allocate to Initial Public Offerings (“IPOs”) of securities, nor do we recommend IPOs to our clients. ITEM 13: REVIEW OF ACCOUNTS For those clients to whom we provide investment advisory services, account reviews are conducted regularly. Ongoing reviews are conducted to watch for variances in allocations, cash inflows and opportunities for tax-loss harvesting. Client performance is reviewed by the IAR on a quarterly basis. All clients (in person or via telephone) are encouraged to review financial planning issues (to the extent applicable), investment objectives, account performance and any personal or financial changes with their IAR, on at least an annual basis and any time there is a material change. We also conduct account reviews upon the occurrence of a triggering event, such as a change in a client’s investment objectives and/or their financial situation, market corrections, and client requests. The custodian provides detailed account statements to clients on at least a quarterly basis. These statements include all transactions for the period including details of the investment advisory fees we charge. We also provide a quarterly performance report to each client. The quarterly report contains detailed information on holdings, including current asset allocation percentages and current and historical performance data. Clients are encouraged to compare the quarterly performance reports from Team Hewins with the account statements received from their custodian. Should there be any material discrepancy, the custodian’s report should be relied upon. The custodian does not verify the accuracy of our fees prior to deducting them from clients’ account(s). If clients have any questions or concerns about the amount they are charged, or any other information on their quarterly report or account statements, they should contact Team Hewins. Team Hewins, LLC – Part 2A of Form ADV Page 24  ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION Team Hewins may seek to enter into agreements with individuals and organizations, some of whom may be affiliated or unaffiliated with Team Hewins, for the referral of clients to us. All such agreements will be in writing and comply with the applicable state and federal regulations. If a client is introduced to Team Hewins by a solicitor, Team Hewins will pay that solicitor a fee in accordance with the applicable federal and state securities law requirements. While the specific terms of each agreement may differ, generally, the compensation will be based upon Team Hewins’ engagement of new clients and the retention of those clients and would be calculated using a varying percentage of the fees paid to Team Hewins by such clients until the account is closed by written authorization from the client. Any such fee shall be paid solely from Team Hewins’ fees and shall not result in any additional charge to the client. Each prospective client who is referred to Team Hewins by a solicitor who is not affiliated with Team Hewins will receive a written disclosure document disclosing whether the solicitor is or is not a current client of Team Hewins, the compensation that will be paid by us to the third party, and a description of any material conflicts of interest on the part of the solicitor in light of Team Hewins’ relationship with the solicitor. In any case, applicable state laws may require these persons to become licensed either as representatives of Team Hewins or as an independent investment adviser. Team Hewins does not receive benefits from third parties for providing investment advice to clients. ITEM 15: CUSTODY We do not take physical custody of our clients’ assets. Per SEC regulations, we may be deemed to have custody if, for certain clients, we or an affiliate: • Act in a capacity of Trustee, Guardian, Power of Attorney, Custodian, or similar authority; • Have entered into an arrangement with the client, per the client’s request, in which we are able to withdraw funds from the client’s account (including withdrawals made pursuant to standing letters of client authorization); and/or • Have client-authorized access to an account, with the ability to withdraw or transfer funds from the account. The SEC requires that firms who have custody for the reasons listed above are subject to an annual surprise audit to be conducted by an independent CPA firm which is registered with and subject to regular inspection by the Public Company Accounting Oversight Board (PCAOB). Team Hewins has complied with the requirements concerning such surprise audits and will continue to do so in the future. Team Hewins is also deemed to have constructive custody over those client accounts where it is able to deduct fees directly from the account. Additionally, certain clients have signed, and can in the future, sign a Standing Letter of Authorization (SLOA) that gives the firm the authority to transfer funds to a third- party as directed by the client in the SLOA. In these cases, the Firm has constructive custody of those assets. Firms with custody must take the following steps: 1. Ensure clients’ managed assets are maintained by a qualified custodian; 2. Have a reasonable belief, after due inquiry, that the qualified custodian will Team Hewins, LLC – Part 2A of Form ADV Page 25  deliver an account statement directly to the client at least quarterly; 3. Confirm that account statements from the custodian contain all transactions that took place in the client’s account during the period covered and reflect the deduction of advisory fees; and 4. Obtain a surprise audit by an independent accountant on the clients’ accounts for which the advisory firm is deemed to have custody. However, the rules governing the direct debit of client fees and SLOAs exempts the Firm from the surprise audit rules if certain conditions (in addition to steps 1 through 3 above) are met. Those conditions are as follows: 1. When debiting fees from client accounts, the firm must receive written authorization from clients permitting advisory fees to be deducted from the client’s account. 2. In the case of SLOAs, the Firm must: (i) confirm that the name and address of the third party is included in the SLOA, (ii) document that the third-party receiving the transfer is not related to the firm, and (ii) ensure that certain requirements are being performed by the qualified custodian. Our clients receive account statements directly from the qualified custodian at least quarterly. We also send clients quarterly reports that we produce using our portfolio accounting system. We strongly urge our clients to compare such reports with the statements received from the qualified custodian. Furthermore, when we calculate our investment management fees and instruct the custodian to remit these fees to us directly from clients’ accounts, the custodian does not verify our calculation of fees. We perform quarterly testing to ensure that our fees are charged in accordance with the client’s Agreement. Clients are strongly encouraged to review the amount of our fees deducted from their accounts and compare them with the fee schedule(s) in their Investment Advisory Agreements. We strongly recommend discussing any assumed or suspected discrepancies, or any questions regarding the fees, with our Chief Compliance Officer, who can be reached at 513-832-5447. Item 16: INVESTMENT DISCRETION A. DISCRETIONARY AND NON-DISCRETIONARY MANAGEMENT As discussed above in Item 4, our clients receiving standard investment advisory services have a choice to engage us on a discretionary or non-discretionary basis. In either case, the client will sign an Investment Advisory Agreement which specifies which kind of service we will render. For both types of clients, we are authorized, by the client, to rebalance the client’s portfolio and perform tax-loss harvesting without specific client approval. Please see Item 8 for an explanation of rebalancing and tax-loss harvesting. Retirement Plan Services provided on an ERISA 3(38) basis, are only offered on a discretionary basis. For clients who retain us on a discretionary basis, the Investment Advisory Agreement grants us full authority to buy, sell or otherwise effect investment transactions involving the assets in the client’s name, including but not limited to the authority to make sub-asset allocation and specific investment adjustments without seeking client approval. With respect to our non-discretionary advisory services, we generally maintain ongoing responsibility to make recommendations based upon the needs and objectives of the client. If such recommendations are accepted by the client, we are responsible for arranging or effecting the purchase or sale. For non- discretionary clients, we do not have the authorization to change either the client’s asset allocation or specific investments without prior approval from the client, except for tax-loss harvesting and rebalancing, as described in Item 8 above. Team Hewins, LLC – Part 2A of Form ADV Page 26  Non-discretionary Service Limitations Clients that determine to engage us on a non-discretionary investment advisory basis must be willing to accept that we cannot execute any account transactions without obtaining prior consent to each transaction from the client. Thus, if we desire to make a change during a time when the client is unavailable, we will generally be unable to execute any account transactions (as we would for our discretionary clients). This inability to trade could result in losses to the client that could otherwise have been avoided. To mitigate the potential consequences of not being able to trade in a timely manner on behalf of a non- discretionary client, we have incorporated a provision into our Investment Advisory Agreement that expressly provides us with the client’s general prior consent to execute transactions on behalf of the non- discretionary client when, in our professional judgment, waiting for client approval could be detrimental to the client because of market or security-specific dynamics. In these instances, the client’s prior consent to effectuate a particular transaction is considered granted when: • We notify the client of our recommendation in advance of effecting the recommended trade; and • We do not receive an objection to our recommendation within the timeframe established by the notice, or within seven (7) days of the date of the notice if no alternative timeframe is given. VOTING CLIENT SECURITIES & SECURITIES CLASS ACTION ITEM 17: POLICY A. PROXY VOTING POLICY Team Hewins will typically vote proxies on behalf of its clients unless otherwise instructed in writing by the client. We have engaged a nonaffiliated third-party proxy voting service provider, Broadridge Investor Communications Solutions, Inc. (“Broadridge”). Broadridge is charged with identifying the proxies that we need to vote, voting those proxies as we have directed them to, and submitting them to the issuer promptly and accurately. Our policy is to vote proxies in our clients’ best interest (i.e., to maximize shareholder value). To that end, we have subscribed to the services of Glass Lewis & Co. (“Glass Lewis”) to provide independent proxy research and voting recommendations. Glass Lewis’ voting and policy recommendations are designed to maximize shareholder value. Team Hewins’ Investment Committee (the “IC”) reviews Glass Lewis’ guidelines and practices no less frequently than annually to determine if their policies continue to be in the best interest of our clients. In the rare event that Glass Lewis does not provide a recommendation, the IC will review the proxy and make a voting recommendation that we believe to be in the clients’ best interest. Should the IC determine that a proxy will have little, or no, impact on shareholder value, we could refrain from voting. When our IC determines the optimal vote, they will review both the short- and long- term implications of the proposal to be voted on. If the IC determines that we have, or are perceived to have, a material conflict of interest in voting a certain proxy, we could choose to remove ourselves from the voting process for that particular ballot. Team Hewins, LLC – Part 2A of Form ADV Page 27  Should a client wish to be voting their own proxies, they should notify Team Hewins no later than at the time of opening their account(s) at a qualified custodian. In such a case, the client will be responsible for voting all proxies in the affected account(s). Team Hewins will not accept authorization to vote proxies in any Courtesy (Non-Managed) accounts. For those of our clients who are qualified retirement plans subject to ERISA, the plan’s governing documents will delegate proxy voting responsibilities to either Team Hewins or another named fiduciary, and our own policies do not preclude us from accepting these responsibilities or providing advice or information about a particular proxy vote to an ERISA client. SECURITIES CLASS ACTION POLICY B. Team Hewins will typically file claims in certain securities class action settlement proceedings on behalf of its clients unless otherwise instructed in writing by the client. In furtherance of its fiduciary duty to each of its clients, the Firm has adopted the following Securities Class Actions Policy as a means of defining the scope of its Class Action Services. Team Hewins does not advise on the merit or value of any claim or alternative legal action a client may wish to take. To the extent any client has questions about their legal rights and/or obligations related to class action settlement proceedings or any other legal matter, the client is advised to consult with a qualified attorney of their choosing. The Firm does not guarantee that any claim it files on behalf of its clients will result in any settlement payment. The Firm’s clients who consent to Team Hewins’ Class Action Services must also consent to such claims being filed and otherwise managed by third parties appointed or retained by the Firm for the purpose of filing and managing such claims. Team Hewins does not file class action settlement claims directly with any claims administrator. The Firm has retained the services of Chicago Clearing Corporation, an unaffiliated third party, to file class action settlement claims on behalf of the Firm and for the benefit of its clients. Chicago Clearing Corporation is responsible for the tracking, review, and analysis of notices regarding the existence of class action settlements, as well as the monitoring of the Firm’s clients’ holdings to pair applicable class action settlements to such holdings. Chicago Clearing Corporation is also responsible for the accounting, reporting, and distribution of any settlement payments resulting from claims filed on behalf of the Firm’s clients. Chicago Clearing Corporation maintains and provides all reports to and for the benefit of the Firm and does not deliver any report directly to any client. Generally, and unless specifically instructed by the Firm otherwise, Chicago Clearing Corporation will distribute settlement proceeds directly to the client’s qualified custodian on behalf of the client. Should the Firm inadvertently receive settlement proceeds on behalf of a client, it shall forward such proceeds to Chicago Clearing Corporation for proper administration of the proceeds pursuant to this Securities Class Actions Policy. Chicago Clearing Corporation does not provide financial, legal, or other professional advice, and, like Team Hewins, is acting only in an administrative capacity. Chicago Clearing Corporation charges a fee equal to 20% of any settlement payment recovered from each claim filed on behalf of a client. This fee is deducted by Chicago Clearing Corporation from the applicable settlement payment before Chicago Clearing Corporation distributes the settlement payment to the applicable client. The Firm does not charge any additional fees for its Class Action Services. Team Hewins, LLC – Part 2A of Form ADV Page 28  ITEM 18: FINANCIAL INFORMATION We do not require prepayment of fees of more than $1,200 per client six months or more in advance. We do not believe there are any financial conditions that are likely to impair our ability to meet our contractual commitments relating to our discretionary authority over certain client accounts. We have not been the subject of a bankruptcy petition. Any Questions? Our Chief Compliance Officer, Michelle McCarthy, remains available to address any questions that a client or prospective client may have regarding the above disclosures, conflicts of interest and other arrangements. You can reach our Chief Compliance Officer at 513-832-5447. Team Hewins, LLC – Part 2A of Form ADV Page 29