A. Firm Information
The Hajdari Group, LLC (“The Hajdari Group” or the “Advisor”) is a registered investment advisor with the U. S.
Securities and Exchange Commission (“SEC”). The Hajdari Group is organized as a limited liability company
(“LLC”) under the laws of the State of New York. The Hajdari Group was founded in June 2009 and became a
registered investment advisor in August 2017. The Hajdari Group is owned and operated by Zaim Hajdari
(President, Senior Managing Director and Chief Compliance Officer). This Disclosure Brochure provides
information regarding the qualifications, business practices, and advisory services provided by The Hajdari
Group.
B. Advisory Services Offered
The Hajdari Group offers advisory services to a variety of Clients, including individuals, high net worth
individuals, families, trusts, estates, charitable organizations, pension and profit-sharing plans, and businesses
(each referred to as a “Client”). The Hajdari Group provides a holistic approach to its advisory services, as
described below, and services are tailored to the unique needs of each Client.
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. The Hajdari Group’s fiduciary commitment is further described in the Advisor’s Code of
Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or
Interest in Client Transactions and Personal Trading.
Investment Management Services
The Hajdari Group provides customized investment advisory solutions for its Clients. This is achieved through
regular personal Client contact and interaction while providing discretionary investment management and
related advisory services. The Hajdari Group’s services typically contain a financial planning element whereby
the Advisor works with each Client to identify the Client’s investment goals and objectives as well as risk
tolerance and financial situation in order to create an investment strategy. The Hajdari Group will typically
implement the investment strategy with its internal management, but may also use unaffiliated money managers
or investment platforms (as described below).
Internal Investment Management - The Hajdari Group customizes its investment management services for its
Clients. Portfolios are primarily constructed using exchange-traded funds (“ETFs”) and, to a lesser extent, open-
end and closed-end mutual funds. The Hajdari Group may also recommend that certain Clients invest in private
offerings, individual stocks, fixed income securities, structured notes, and other types of investments, as
appropriate, to meet the needs of each particular Client. Investment portfolios are typically reviewed at least
annually in connection with Client reviews. The Advisor may retain certain legacy investments based on
portfolio fit and/or tax considerations.
The Hajdari Group generally employs a long-term investment approach for Clients, but may buy, sell or re-
allocate positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. The Hajdari Group will construct, implement and monitor the portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to
place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to
acceptance by the Advisor.
At no time will The Hajdari Group accept or maintain custody of a Client’s funds or securities, except for the
limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated
account[s] at the Custodian, pursuant to the terms of the advisory agreement, please see Item 12 – Brokerage
Practices.
For certain securities held in discretionary Client accounts, the Advisor is unable to transact in such securities
on the Client’s behalf (e.g., in the case of a private offering, only the Client is permitted to subscribe for interests
in the security or initiate a withdrawal request). In addition, certain securities held in discretionary Client
accounts were directed by the Client in an unsolicited trade and not recommended by the Advisor. Although the
Advisor monitors such investments on an ongoing basis, the Advisor deems the services provided with respect
to such investments to be non-discretionary since it does not have the ability to purchase or sell such securities
without its Clients’ involvement and authorization.
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Use of Independent Managers - The Hajdari Group may recommend to Clients that all or a portion of their
investment portfolio be implemented by utilizing one or more unaffiliated money managers or investment
platforms (collectively “Independent Managers”). Independent Managers may be sourced directly or accessed
through an investment management platform. The Client will typically be required to enter into a separate
agreement with the Independent Manager[s] that defines the terms under which the independent manager will
provide its services.
The Hajdari Group serves as the Client’s primary advisor and relationship manager. However, the Independent
Manager[s] will assume discretionary authority for the day-to-day
investment management of those assets
placed under their control. The Hajdari Group performs initial and ongoing oversight and due diligence over
each Independent Manager to ensure the strategy remains aligned with the Client’s investment objectives and
overall best interest. The Advisor will assist and advise the Client in establishing investment objectives for their
account[s], the selection of the Independent Manager[s], and defining any restrictions on the account[s].
The Client, prior to entering into an agreement with an Independent Manager, will be provided with the
Independent Manager’s Form ADV Part 2A (or a brochure that makes the appropriate disclosures).
Financial Planning Services
The Hajdari Group will provide a variety of financial planning services and consulting services, typically pursuant
to a written financial planning agreement. Services are provided to address several areas of a Client’s financial
situation, depending on the Client’s goals and objectives. Planning or consulting may encompass one or more
areas of need, including, but not limited to investment planning, retirement planning, distributions, personal
savings, education savings, spending, insurance needs and other areas of a Client’s financial situation. The
Hajdari Group may deliver specific planning modules to the Client or a comprehensive plan, based on the needs
of the Client.
In certain circumstances, The Hajdari Group may also refer Clients to an accountant, attorney or other specialist,
as appropriate for the Client’s unique situation. For certain financial planning engagements, the Advisor will
generally provide a written report that contains observations and recommendations. For consulting or ad-hoc
engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed
within six months of the contract date, assuming all information and documents requested are provided
promptly.
Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the
prospective advisory Client. For example, the Advisor has an incentive to recommend that prospective advisory
Clients engage the Advisor for investment management services or to increase the level of investment assets
with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Prospective advisory
Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing
relationship with the Advisor. If the prospective advisory Client elects to act on any of the recommendations
made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor.
Retirement Plan Advisory Services
The Hajdari Group provides advisory services to retirement plans (each a “Plan”) and the company sponsor (the
“Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in
meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs
of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Review
• Investment Oversight Services (ERISA 3(21))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services
These services are provided by The Hajdari Group serving in the capacity as a fiduciary under the Employee
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Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the
Plan Sponsor is provided with a written description of The Hajdari Group’s fiduciary status, the specific services to
be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging The Hajdari Group to provide advisory services, each Client is required to enter into one or
more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor
and the Client. These services may include:
• Establishing an Investment Strategy – The Hajdari Group in connection with the Client, will develop a
strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – The Hajdari Group will develop a strategic asset allocation that is targeted to seek to
meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – The Hajdari Group will develop a portfolio for the Client that is intended to meet
the stated goals and objectives of the Client.
• Investment Management and Supervision – The Hajdari Group will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
The Hajdari Group does not offer a wrap fee program. However, certain Independent Managers may include
securities transaction fees as part of the manager’s fee.
E. Assets Under Management
As of December 31, 2023, The Hajdari Group manages $84,685,050 in Client assets, $75,489,000 of which is
managed on a discretionary basis and $9,196,000 on a non-discretionary basis. Clients may request more
current information at any time by contacting the Advisor.