HRA is an investment adviser registered with the Securities and Exchange Commission and is a
limited liability company (LLC) formed under the laws of the State of Texas.
• Greg L. Hutto
is the Chief Compliance Officer (CCO),100% Owner and President of HRA.
Full details of the education and business background of Greg L. Hutto are provided at
Item 19 of this Disclosure Brochure.
• HRA filed its initial application to become registered as an investment adviser in August
2012.
Introduction
The investment advisory services of HRA are provided to you through an appropriately licensed
and qualified individual who is an investment adviser representative of HRA (referred to as your
investment adviser representative throughout this brochure).
Your investment adviser representative typically is not an employee of HRA; rather, your
investment adviser representative typically is an independent contractor of HRA.
Your investment adviser representative is limited to providing the services and charging investment
advisory fees in accordance with the descriptions detailed in this brochure.
Description of Advisory Services
The following are descriptions of the primary advisory services of HRA. Please understand that a
written agreement, which details the exact terms of the service, must be signed by you and HRA
before we can provide you the services described below.
Wealth Diversification Program Services – HRA offers asset management services, which
involves HRA providing you with continuous and ongoing supervision over your specified accounts.
You must appoint our firm as your investment adviser of record on specified accounts (collectively,
the “Account”). The Account consists only of separate account(s) held by qualified custodian(s)
under your name. The qualified custodians maintain physical custody of all funds and securities of
the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash,
exercise or delegate proxy voting and receive transaction confirmations) of the Account.
The Account is managed by us based on your financial situation, investment objectives and risk
tolerance. We actively monitor the Account and provide advice regarding buying, selling,
reinvesting or holding securities, cash or other investments of the Account.
We will need to obtain certain information from you to determine your financial situation and
investment objectives. You will be responsible for notifying us of any updates regarding your
financial situation, risk tolerance or investment objective and whether you wish to impose or modify
existing investment restrictions; however we will contact you at least annually to discuss any
changes or updates regarding your financial situation, risk tolerance or investment objectives. We
are always reasonably available to consult with you relative to the status of your Account. You
have the ability to impose reasonable restrictions on the management of your accounts, including
the ability to instruct us not to purchase certain securities.
It is important that you understand that we manage investments for other clients and may give them
advice or take actions for them or for our personal accounts that is different from the advice we
provide to you or actions taken for you. We are not obligated to buy, sell, or recommend to you any
security or other investment that we may buy, sell or recommend for any other clients or for our
own accounts.
Conflicts may arise in the allocation of investment opportunities among accounts that we manage.
We strive to allocate investment opportunities believed to be appropriate for your account(s) and
other accounts advised by our firm among such accounts equitably and consistent with the best
interests of all accounts involved. However, there can be no assurance that a particular investment
opportunity that comes to our attention will be allocated in any particular manner. If we obtain
material, non-public information about a security or its issuer that we may not lawfully use or
disclose, we have absolutely no obligation to disclose the information to any client or use it for any
client’s benefit.
Financial Planning & Consulting Services - HRA offers financial planning services, through the
Total Client Profile program. The Total Client Profile Program is a financial planning process that
helps clients go beyond the traditional “how much is needed and where should I put it” emphasis
used by traditional financial planning tools to provide a better understanding of what their money
and wealth represent in their lives. We encourage clients to talk about the seven facets of their
lives; their values, goals, important relationships, assets, advisors, interests, and the current
processes used. Once these issues are thoroughly discussed the answers are mapped to
determine if there are certain factors that overlap or occur more or less frequently than what might
be expected. This process allows our advisors to get to know clients on a deeper level and gain an
understanding of what the client feels is the most important things concerning their money.
We provide full written financial plans, which typically address the following topics: Investment
Planning, Retirement Planning, Insurance Planning, Tax Planning, Education Planning, Portfolios
Review, Asset Allocation, Budgeting, Divorce Settlements, General Tax Planning and Business
Succession Planning. When providing financial planning and consulting services, th
e role of your
investment adviser representative is to find ways to help you understand yo
ur overall financial
situation and help you set financial
objectives. We also provide modular written financial plans
which only cover those specific areas of concern mutually agreed upon by you and us. A modular
written financial plan is limited or segmented and does not involve the creation of a full written
financial plan. You should be aware that there are important issues that may not be taken into
consideration when your investment adviser representative develops his or her analysis and
recommendations under a modular written financial plan. Written financial plans prepared by us
under this Agreement do not include specific recommendations of individual securities.
We also offer consultations in order to discuss financial planning issues when you do not need a
written financial plan. We offer a one-time consultation, which covers mutually agreed upon areas
of concern related to investments or financial planning. We also offer “as-needed” consultations,
which are limited to consultations in response to a particular investment or financial planning issue
raised or request made by you. Under an “as-needed” consultation, it will be incumbent upon you
to identify those particular issues for which you are seeking our advice or consultation on.
In addition to these services, we offer ongoing advisement consultations to participants in
retirement plans (401(k) plans, profit sharing plans, etc.). When providing these services, we
review your financial situation, goals, and objectives as well as the investment options available in
the retirement plan. We will review your retirement plan account at quarterly intervals and will
make such recommendations from the list of available investment options in your retirement plan
account as are deemed appropriate and consistent with your stated investment objectives and risk
tolerance. These services do not constitute asset management services for your retirement plan
account; we do not have investment discretion or trading authority over your retirement plan
account. You determine whether or not to implement our advice. The implementation of any
trades in your retirement plan account is your responsibility.
Our financial planning and consulting services do not involve implementing any transaction on your
behalf or the active and ongoing monitoring or management of your investments or accounts. You
have the sole responsibility for determining whether to implement our financial planning and
consulting recommendations. To the extent that you would like to implement any of our investment
recommendations through HRA or retain HRA to actively monitor and manage your investments,
you must execute a separate written agreement with HRA for our asset management services.
Retirement Plan Services - HRA offers retirement plan services to retirement plan sponsors and
to individual participants in retirement plans. For a corporate sponsor of a retirement plan, our
retirement plan services can include, but are not limited to, the following services:
Fiduciary Management Services
HRA provides clients with the following Fiduciary Retirement Plan Management Services:
• Discretionary Management Services. HRA will provide you with continuous and ongoing
supervision over the designated retirement plan assets. HRA will actively monitor the
designated retirement plan assets and provide advice regarding buying, selling, reinvesting
or holding securities, cash or other investments of the Plan. We have discretionary
authority to make all decisions to buy, sell or hold securities, cash or other investments for
the designated retirement plan assets in our sole discretion without first consulting with
you. We also have the power and authority to carry out these decisions by giving
instructions, on your behalf, to brokers and dealers and the qualified custodian(s) of the
Plan for our management of the designated retirement plan assets.
If you elect to utilize any of HRA’s Fiduciary Management Services, then HRA will be acting as an
Investment Manager to the Plan, as defined by ERISA section 3(38), with respect to our Fiduciary
Management Services, and HRA hereby acknowledges that it is a fiduciary with respect to its
Fiduciary Management Services.
We can also meet with individual participants to discuss their specific investment risk tolerance,
investment time frame and investment selections.
Securities and other types of investments all bear different types and levels of risk. Those risks are
typically discussed with clients in defining the investment policies and objectives that will guide
investment decisions for their qualified plan accounts. Upon request, as part of our retirement plan
services, we can discuss those investments and investment strategies that we believe may tend to
reduce these risks for a particular client’s circumstances and plan participants.
Clients and plan participants must realize that obtaining higher rates of return on investments
entails accepting higher levels of risk. Based upon discussions with the client, we will attempt to
identify the balance of risks and rewards that is appropriate and comfortable for the client and other
employees. It is still the clients’ responsibility to ask questions if the client does not fully
understand the risks associated with any investment. All plan participants are strongly encouraged
to read prospectuses, when applicable, and ask questions prior to investing.
We strive to render our best judgment for clients. Still, HRA cannot assure that investments will be
profitable or assure that no losses will occur in their portfolios. Past performance is an important
consideration with respect to any investment or investment advisor, but it is not necessarily an
accurate predictor of future performance.
HRA will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c), to you any
change to the information that we are required to disclose under ERISA Regulation Section
2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on
which we are informed of the change (unless such disclosure is precluded due to extraordinary
circumstances beyond our control, in which case the information will be disclose as soon as
practicable).
In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty
(30) days following receipt of a written request from the responsible plan fiduciary or Plan
Administrator (unless such disclosure is precluded due to extraordinary circumstances beyond our
control, in which case the information will be disclosed as soon as practicable) all information
related to the Qualified Retirement Plan Agreement and any compensation or fees received in
connection with the Agreement that is required for the Plan to comply with the reporting and
disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued
thereunder.
If we make an unintentional error or omission in disclosing the information required under ERISA
Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as
soon as practicable, but no later than thirty (30) days from the date on which we learns of such
error or omission.
Annuity Sub-Account Management Services - Under our sub-account management services,
HRA manages your annuity or variable life contract by selecting, monitoring and exchanging as
necessary between investments available from the insurance company issuing the annuity or
variable life contract.
Under this program, we assist you in completing a questionnaire which details your financial goals,
risk tolerance and time horizon. You will have the opportunity to list in your investment advisory
agreement with our firm any reasonable restrictions on the investments that may be utilized by
HRA. You will be responsible for notifying us of any updates regarding your financial situation, risk
tolerance or investment objective and whether you wish to impose or modify existing investment
restrictions; however, we will contact you at least annually to discuss any changes or updates
regarding your financial situation, risk tolerance or investment objectives.
Once you have provided us with the necessary information and made the appropriate
authorizations, HRA utilizes limited discretionary authority to select or exchange among the
investments available under your annuity or variable life contract in accordance with your disclosed
investment objective and risk tolerance. HRA may utilize signal providers for guidance regarding
investment strategies, asset allocations and timing of exchanges. HRA will monitor your sub-
accounts and exchange sub-accounts as necessary and in accordance with your investment
objective and risk tolerance.
Limits Advice to Certain Types of Investments
HRA provides investment advice on the following types of investments:
• Mutual Funds
• Exchange Traded Funds (ETFs)
• Separately Managed Accounts (SMAs)
• Hedge Funds
• Exchange-listed Securities
• Securities Traded Over-the-Counter
• Corporate Debt Securities
• Certificates of Deposit
• Municipal Securities
• Variable Annuities
• Variable Life Insurance
• US Government Securities
• Options Contracts on Securities
• Interests in Partnerships Investing in Real Estate
• Non-publicly Traded Offerings such as BDCs (Business Development Companies) and
REITs
Although we generally provide advice only on the products previously listed, we reserve the right to
offer advice on any investment product that may be suitable for each client’s specific
circumstances, needs, goals and objectives.
It is not our typical investment strategy to attempt to time the market, but we may increase cash
holdings as deemed appropriate based on your risk tolerance and our expectations of market
behavior. We may modify our investment strategy to accommodate special situations such as low
basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or
special tax situations.
(Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more
information.)
Tailor Advisory Services to Individual Needs of Clients
HRA’s advisory services are always provided based on your individual needs. For example, this
means that when we provide asset management services, you are given the ability to impose
restrictions on the accounts we manage for you, including specific investment selections and
sectors. We work with you on a one-on-one basis through interviews and questionnaires to
determine your investment objectives and suitability information. Our financial planning and
consulting services are always provided based on your individual needs. We work with you on a
one-on-one basis through interviews and questionnaires to determine your investment objectives
and suitability information when providing financial planning and consulting services.
We will not enter into an investment adviser relationship with a prospective client whose investment
objectives may be considered incompatible with our investment philosophy or strategies or where
the prospective client seeks to impose unduly restrictive investment guidelines.
When managing client accounts through our firm’s Asset Management Services program, we may
manage a client’s account in accordance with one or more investment models. When client
accounts are managed using models, investment selections are based on the underlying model
and we do not develop customized (or individualized) portfolio holdings for each client. However,
the determination to use a particular model or models is always based on each client’s individual
investment goals, objectives and mandates.
Client Assets Managed by HRA
The amount of client assets managed by the firm totaled $194,525,714 as of December 31, 2023.
$194,525,714 are managed on a discretionary basis and $0 are managed on a non-discretionary
basis.