The Firm Hamilton, Manor & Associates is a comprehensive tax and wealth management firm located in California since 1986. In 2011, the firm registered as an investment adviser to offer financial planning advisory services. In 2015 the registered investment adviser expanded the advisory services to include asset management. The firm is committed to staying current on applicable legislation and financial markets in order to proactively help our clients make the “right” decision about their financial matters. We seek to accomplish our mission through education, communication and service that exceeds our client’s expectations. Our proactive, forward-looking analysis seeks to capitalize on extensive research into global monetary and economic trends in order to reduce risk and provide above average performance. We monitor multiple research sources, including, but not limited to: LPL Financial, Goldman Sachs, JP Morgan, the Harvard & Yale Foundations, CalPERS Pension Plan, PIMCO, and Capital Research Management. Once we have constructed our asset allocation models based on the broad research sources, we then use third party money manager analyses and personal interviews to help select the best money managers and products available for each of the asset classes we use in our clients’ portfolios. We have established a system of periodic portfolio reviews and client meetings. During these reviews we personally discuss any changes being recommended to the client’s investment portfolio and items we have discovered that may pertain to them while monitoring market and legislative changes. These periodic reviews provide the client with an opportunity to ask questions about other financially related topics but were not urgent enough matters to call us about before their next periodic review. This comprehensive service provides our clients with the confidence that their money is being actively managed by a team of professionals who are staying current with the complicated financial environment for their benefit. In return, this affords our clients the luxury to concentrate on what they enjoy. Management Keith Hamilton is the sole owner of Hamilton, Manor & Associates. He is also a registered principal with LPL Financial, a separate unaffiliated legal entity and FINRA/SIPC member broker/dealer offering securities transactions on a commission basis. He graduated from Oregon State University in 1984 with a Bachelor of Science degree in Accounting and a Bachelor of Science degree in Computer Science. He relocated to San Diego in 1984 and currently is a resident in the community of La Jolla. He is married to his wife Wendy and has two children, Reed and Brandon. In his spare time, Keith enjoys playing tennis. In addition, Keith has been a Certified Financial Plannertm since 1991 and is a member of the Financial Planning Association and has held his Life, Health, and Disability insurance license with the State of California since 1986. He has also been a licensed tax preparer with the State of California since 1985 and a member of the California Society of Certified Public Accountants. His practice specialty is investment management combined with income and estate tax reduction strategies. Prior to his financial services career, Keith was a computer programmer for Cubic Corporation. Asset Management Hamilton, Manor & Associates provides discretionary (with permission) and non-discretionary fee based investment advisory services for compensation primarily to individual clients and high-net worth individuals and corporate clients based on the individual goals, objectives, time horizon, and risk tolerance of each client. Portfolio management services include, but are not limited to, the following:
• Investment strategy • Investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring The individuals associated with Hamilton, Manor & Associates are appropriately licensed, and authorized to provide advisory services on behalf of Hamilton, Manor & Associates. Individuals associated with Hamilton, Manor & Associates are also registered representatives of LPL Financial, a separate legally unaffiliated entity and SEC registered broker/dealer, a member of the Financial Regulatory Authority ("FINRA") and the Securities Investors Protection Corporation (“SIPC”). Any securities transactions executed by investment adviser representatives of Hamilton, Manor & Associates in their capacity of a registered representative of LPL Financial shall be directed to LPL Financial for execution. However, clients retain the right to execute securities transaction through the broker/dealer of their choice. Hamilton, Manor & Associates and LPL Financial are not affiliated legal entities. Any and all material conflicts of interest are disclosed herein. Strategic Wealth Management (SWM) Strategic Wealth Management (SWM) is the name of a custodial account offered through LPL Financial to support investment advisory services provided by Hamilton, Manor & Associates. Within a SWM account, investment advisor representatives provide advice on the purchase and sale of various types of investments, such as mutual funds, exchange-traded funds (“ETFs”), variable annuity subaccounts, real estate investment trusts (“REITs”), equities, fixed income securities, options and structured products, among others. The advice is tailored to the individual needs of the client based on the investment objective chosen by the client in order to help assist clients in attempting to meet their financial goals. Accounts are reviewed on a regular basis and rebalanced as necessary according to each client’s investment profile. More specific account information and acknowledgments are further detailed in the account opening documents. Investment Advisors Representatives can offer SWM as a wrap fee program account or a non- wrap fee program account. The accounts offer the same investment choices and are managed in the same manner, but the fee structure is different. For a non-wrap fee program account, clients are charged transaction fees in addition to the advisory fee whereas for a wrap fee program account, the transactions fees are absorbed (wrapped) as part of the advisory fee, which makes it a “Wrap Fee Program”. A wrap fee program is a comprehensive advisory account with a single fee that covers a bundle of services; such as, portfolio management, advice, and investment research as well as trade execution, custody and reporting fee. The fee is not based directly upon advisory services or the execution of transactions. Accounts with assets of $400,000 and above are generally held in a wrap fee program account whereas accounts with less the $400,000 are held in a non-wrap fee account. Hamilton, Manor & Associates is the sponsor and portfolio manager of a wrap fee program – additional details are provided in Appendix-1. Generally there is no minimum account balance required for a SWM account. In certain instances, Hamilton, Manor & Associates may require a minimum account size. LPL Financial Sponsored Programs
• Optimum Market Portfolios (OMP) The Optimum Market Portfolios (OMP) program offers clients the ability to participate in a professionally managed asset allocation program designed by LPL Financial. There are up to six Optimum Funds that may be purchased within an OMP account: Optimum Large Cap Growth Fund, Optimum Large Cap Value Fund, Optimum Small Cap Growth Fund, Optimum Small Cap Value Fund, Optimum International Fund and Optimum Fixed Income Fund. Hamilton, Manor & Associates will obtain the necessary financial data from each client and then select the proper fund portfolio program. While Hamilton, Manor & Associates selects the proper portfolio program, LPL Financial will manage the underlying Optimum Funds on a discretionary basis consistent with the portfolio program objectives. LPL Financial does not directly manage fund assets on behalf of any particular client. LPL follows an asset allocation investment style in constructing portfolios for the Program. Asset allocation methodology is implemented by combining investments representing various asset classes that react differently to varying market conditions. Thus, if one asset class reacts negatively to certain market events, the potential exists for another asset class to react positively. As with any investment strategy, there is no guarantee that the use of an asset allocation strategy will produce favorable results. Hamilton, Manor & Associates is responsible for educating the client about this investment style in advance of opening the Account by explaining the various asset classes (e.g., large cap growth, large cap value, etc.) being used within the selected portfolio. This educational process continues throughout the time that the client maintains the account. OMP is one of several portfolio platforms centrally managed by LPL Financial. OMP enables advisors of Hamilton, Manor & Associates to manage client assets through diversified asset allocation models, professional money management, automatic rebalancing, and online marketing and sales support. A minimum account value of $15,000 is required for OMP.
• Personal Wealth Portfolios (PWP) Personal Wealth Portfolios offers clients an asset management account using third party adviser portfolio allocation models designed by LPL Financial. The PWP program is a unified managed account program in which LPL and Advisor provide ongoing investment advice and management. In PWP, clients invest in asset allocation portfolios (“Portfolios”) designed by LPL’s Research Department, which include a combination of mutual funds, exchange-traded funds (“ETFs”) and investment models (“Models”) provided to LPL by third party money managers ("PWP Advisors"). The Models typically consist of equity and fixed income securities, but may include investment company securities. LPL’s Research Department selects the mutual funds, ETFs and Models to be made available in a Portfolio. The Advisor obtains the necessary financial data from the client, assists the client in determining the suitability of the program and assists the client in setting an appropriate investment objective. The Advisor, or client with the assistance of the Advisor, selects a Portfolio based on client’s investment objective and then selects among the mutual funds, ETFs and/or Models available in the Portfolio. If client authorizes Advisor to take discretion to make such selections on client’s behalf, the discretionary authority will be set out in the Account Agreement and Application signed by the client. Neither LPL nor a third party money manager directly provides advisory services to the clients of Hamilton, Manor & Associates. The third party money managers selected by LPL Financial for a particular program manage the portfolio without regard for any particular client of Hamilton, Manor & Associates. Hamilton, Manor & Associates is solely responsible for the advisory services provided and selecting the proper portfolio of third party money managers. Hamilton, Manor & Associates is not acting as a cash solicitor for LPL Financial or other third party money managers. A minimum account value of $250,000 is required for PWP.
• Model Wealth Portfolios (MWP) Model Wealth Portfolios Program offers clients a professionally managed mutual fund asset allocation program. Hamilton, Manor & Associates investment advisor representatives will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program and assist the client in setting an appropriate investment objective. The Advisor will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s Research Department is responsible for selecting the mutual funds within a model portfolio and for making changes to the mutual funds selected. The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds including in certain circumstances exchange traded funds and to liquidate previously purchased securities. The client will also authorize LPL to effect rebalancing for MWP accounts. In the future, the MWP program may make available model portfolios designed by strategists other than LPL’s Research Department. If such models are made available, Advisor will have discretion to choose among the available models designed by LPL or outside strategists. A minimum account value of $100,000 is required for MWP.
• Manager Access Select (MAS) Manager Access Select provides clients access to the investment advisory services of professional portfolio management firms for the individual management of client accounts. Advisor will assist client in identifying a third party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made available by LPL. The Portfolio Manager manages client’s assets on a discretionary basis. Advisor will provide initial and ongoing assistance regarding the Portfolio Manager selection process. A minimum account value of $100,000 is required for Manager Access Select, however, in certain instances, the minimum account size may be lower or higher.
• Manager Access Network (MAN) Manager Access Network enables high-net-worth investors to access a variety of institutional portfolio managers at significantly lower account minimums. By using separate account managers, clients can enjoy a higher level of specialization and service through the ownership of individual securities. A broad range of portfolio managers and multiple investment styles are available, including equity, fixed income, asset classes, mutual funds, ETFs, and specialty strategies. Clients contract directly with the portfolio managers for discretionary asset management services. LPL Financial provides brokerage, custodial, and administrative services to clients. Due diligence and portfolio monitoring is not provided by LPL Research. Minimum account balances vary by portfolio manager, but typically start at $100,000 for equity strategies and $250,000 for fixed income strategies. Hamilton, Manor & Associates offers asset management on a discretionary basis. As of March 18, 2024 the firm has $42,389,221 of discretionary assets and $105,322,140 of non-discretionary assets under management. Retirement Plan Rollovers An employee generally has four (4) options for their retirement plan when they leave an employer: 1. Leave the money in his/her former employer’s plan, if permitted 2. Rollover the assets to his/her new employer’s plan if one is available and permitted 3. Rollover to an Individual Retirement Account (IRA), or 4. Cash out the account value, which has significant tax considerations Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage here are a few points to consider before you do so:
• Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments.
• Employer retirement plans generally have a more limited investment menu than IRAs.
• Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds.
• Your current plan may have lower fees than our fees. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of interest because Investment Advisor Representatives have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your

needs. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. An employee will typically be investing only in mutual funds, you should understand the cost structure of the share classes, available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. Clients should understand the various products and services they might take advantage of at an IRA provider and the potential costs of those products and services.
• Our strategy may have higher risk than the option(s) provided to you in your plan.
• Your current plan may also offer financial advice.
• If you keep your assets titled in a 401k or retirement account, participants could potentially delay their required minimum distribution beyond age.
• A 401(k) may offer more liability protection than a rollover IRA; each state may vary.
• Participants may be able to take out a loan on your 401k, but not from an IRA.
• IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home.
• If company stock is owned in a plan, participants may be able to liquidate those shares at a lower capital gains tax rate.
• Plans may allow Advisor to be hired as the manager and keep the assets titled in the plan name. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult with an attorney if you are concerned about protecting your retirement plan assets from creditors. It is important to understand the differences between these types of accounts and to decide whether a rollover is the best option. Prior to proceeding, if you have questions contact your Investment Adviser Representative, or call our main number as listed on the cover page of this brochure. When Advisor provides 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 make money creates 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. Under this special rule’s provisions, 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. Advisor also provides educational services to retirement plan participants with assets that could potentially be rolled-over to an IRA advisory account. Education is based on a particular Client’s financial circumstances and best interests. Again, Advisor has an incentive to recommend such a rollover based on the compensation received, which is mitigated by the fiduciary duty to act in a Client’s best interest and acting accordingly. Planning Strategies for Families and Individuals
• Retirement – planning an investment strategy with the objective of providing inflation-adjusted income for life.
• College / Education – planning to pay the future college / education expenses of a child or grandchild.
• Major Purchase – Evaluation of the pros and cons of home ownership verse renting as well as buying or leasing a car, for example.
• Divorce – planning for the financial impact of divorce such as change in income, retirement benefits and tax considerations.
• Insurance Needs – planning for the financial needs of survivors to satisfy such financial obligations as housing, dependent child care and spousal arrangements as well as education.
• Final Expenses – planning to leave assets to cover final expenses such as funeral, debts and potential business continuity.
• Estate Planning – planning that focuses on the most efficient and tax friendly option to pass on an estate to a spouse, other family members or a charity.
• Cash Flow/ Budget Planning – planning to manage expenses against current and projected income.
• Wealth Accumulation – planning to build wealth within a portfolio that takes into consideration risk tolerance and time horizon.
• Tax Planning – planning a tax efficient investment portfolio to maximize deductions and off-setting losses.
• Investment Planning – planning an investment strategy consistent with a particular objectives, time horizons and risk tolerances.
• Inheritance Planning – planning for a tax efficient method to pass wealth to the next generation.
• Employee and Government Benefits Analysis – analysis of the cost and premiums as well as the pre and post retirement coverage options. Planning Strategies for Businesses
• Business Entity Planning – review the various forms of business structures in relation to liability and income tax considerations.
• Qualified Retirement Plans – evaluate the types of retirement plans established by an employer for the benefit of the company’s employees.
• Stock Option Planning – planning to maximize the value of employer issued stock options and optimize what to exercise and what to hold.
• Key Person Planning – evaluate the life insurance needs required in the event of the sudden loss of a key executive in order to buy time to find a new person or to implement other strategies to continue the business.
• Executive Benefits – planning to attract, reward and retain top executive talent.
• Deferred Compensation Plans – planning for the use of tax deferred funds to be withdrawn and taxed at some point in the future.
• Business Succession Planning – planning for the continuation of a business after key executives move on to new opportunities, retire or pass away with the use of buy-sell agreements, key-man insurance and engaging independent legal counsel as needed. Hourly Consulting Services Hamilton, Manor & Associates, through its investment advisor representatives, may provide consulting services on an hourly basis. These services may include, as selected by the client in the consulting agreement. The services take into account information collected from the client such as financial status, investment objectives and tax status, among other data. The investment advisor representatives may or may not deliver to the client a written analysis or report as part of the services. The investment advisor representatives tailor the hourly consulting services to the individual needs of the client based on the investment objective chosen by the client. The engagement terminates upon final consultation with the client. The negotiated hourly fee for these services will generally not exceed $250 but may exceed $250 as circumstances warrant due to client specific complexities or the degree of expertise required. Retirement Plan Consulting Investment advisor representatives of Hamilton, Manor & Associates may assist clients that are trustees or other fiduciaries to retirement plans (“Plans”) by providing fee-based consulting and/or advisory services. Investment advisor representatives may perform one or more of the following services, as selected by the client in the client agreement:
• Assistance in the preparation or review of an investment policy statement (“IPS”) for the Plan based upon consultation with client to ascertain Plan’s investment objectives and constraints.
• Acting as a liaison between the Plan and service providers, product sponsors or vendors.
• Ongoing monitoring of investment manager(s) or investments in relation to the criteria specified in the Plan’s IPS or other written guidelines provided by the client to IAR.
• Preparation of reports describing the performance of Plan investment manager(s) or investments, as well as comparing the performance to benchmarks.
• Ongoing recommendations, for consideration and selection by client, about specific investments to be held by the Plan or, in the case of a participant-directed defined contribution plan, to be made available as investment options under the Plan.
• Education or training for the members of the Plan investment committee with regard to various matters, including plan features, retirement readiness matters, service on the committee, and fiduciary responsibilities.
• Assistance in enrolling Plan participants in the Plan, including conducting an agreed upon number of enrollment meetings. As part of such meetings, IARs may provide participants with information about the Plan, which may include information on the benefits of Plan participation, the benefits of increasing Plan contributions, the impact of pre-retirement withdrawals on retirement income, the terms of the Plan and the operation of the Plan. If the Plan makes available publicly traded employer stock (“company stock”) as an investment option under the Plan, investment advisor representatives do not provide investment advice regarding company stock and are not responsible for the decision to offer company stock as an investment option. In addition, if participants in the Plan may invest the assets in their accounts through individual brokerage accounts, a mutual fund window, or other similar arrangement, or may obtain participant loans, investment advisor representatives do not provide any individualized advice or recommendations to the participants regarding these decisions. In addition, if client elects to engage an investment advisor representatives to perform ongoing investment monitoring and ongoing investment recommendation services to a Plan subject to ERISA in the client agreement, such services will constitute “investment advice” under Section 3(21)(A)(ii) of ERISA. Therefore, the investment advisor representatives will be deemed a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of ERISA in connection with those services. Clients should understand that to the extent the IAR is engaged to perform services other than ongoing investment monitoring and recommendations, those services are not “investment advice” under ERISA and therefore, the IAR will not be a “fiduciary” under ERISA with respect to those other services. From time to time the IAR may make the Plan or Plan participants aware of and may offer services available from IAR that are separate and apart from the services provided under Retirement Plan Consulting. Such other services may be services to the Plan, to a client with respect to client's responsibilities to the Plan and/or to one or more Plan participants. In offering any such services, the IAR is not acting as a fiduciary under ERISA with respect to such offering of services. If any such separate services are offered to a client, the client will make an independent assessment of such services without reliance on the advice or judgment of the IAR. Such service may include:
• Assistance with investment education seminars and meetings for Plan participants. Such meetings may be on a group or individual basis, and may include information about the investment options under the Plan (e.g., investment objectives, risk/return characteristics, and historical performance), investment concepts (e.g., diversification, asset classes, and risk and return), and how to determine investment time horizons and assess risk tolerance. Such meetings do not include specific investment advice about investment options under the Plan as being appropriate for a particular participant.
• Assistance at client’s direction in making changes to investment options under the Plan.
• As part of the ongoing investment recommendation service set out above, assistance in identifying investment options in connection with the “broad range” requirement of Section 404(c) of the Employee Retirement Income Security Act of 1974 (“ERISA”).
• As part of the ongoing investment recommendation service set out above, assistance in identifying an investment fund product or model portfolio in connection with the definition of a “Qualified Default Investment Alternative” (“QDIA”) under ERISA.
• Assistance with the preparation, distribution and evaluation of Request for Proposals, finalist interviews, and conversion support in connection with vendor analysis and service provider support.
• Preparation of comparisons of Plan data (e.g., regarding fees and services and participant enrollment and contributions) to data from the Plan’s prior years and/or a benchmark group of similar plans.
• Assistance in identifying the fees and other costs borne by the Plan for, as specified by client, investment management, recordkeeping, participant education, participant communication and/or other services provided with respect to the Plan. Other Considerations Neither the firm nor any investment advisor representative are registered or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or a representative of the foregoing. Advisory agreements may not be assigned or transferred in any manner by any party without the written consent of all parties receiving or rendering services hereunder; provided that Advisor may assign an agreement upon consent of the client. An advisory agreement may be terminated by any party effective upon receipt of written notice to the other parties. The client will be entitled to a prorated refund of any pre-paid quarterly Account Fee based upon the number of days remaining in the quarter after the Termination Date. Clients need to understand that in the event of death or incapacity during the term of an advisory agreement, the authority of Hamilton, Manor & Associates under an advisory agreement shall remain in full force and effect until such time as Hamilton, Manor & Associates is notified otherwise in writing by the authorized representative of a client or a client’s estate. Termination of an advisory agreement will not affect the liabilities or obligations of the parties from transactions initiated prior to termination. Economic commentaries and research provided by LPL Financial are provided at no cost and not contingent upon the amount of business processed through LP Financial. Securities transactions are generally effected through LPL Financial as the executing broker/dealer by the IAR in their capacity of registered representative of the LPL Financial broker/dealer. Clients are however able to execute transactions at a broker/dealer of their choice. LPL Financial is an unaffiliated separate legal entity from Keith Hamilton, Inc. The IAR may receive additional cash or non-cash compensation from advisory product sponsors. Such compensation may not be tied to the sales of any products. Compensation may include such items as gifts valued at less than $100 annually, an occasional dinner or ticket to a sporting event, or reimbursement in connection with educational meetings or marketing or advertising initiatives.