HSWM offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to HSWM rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with HSWM setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). HSWM has been operating as an investment advisory firm since May 2019 and is owned by Steven J. Hubbell, Carson W. Strickland and Todd S. Hubbell through their respective limited liability holding companies. As of 12/31/23, HSWM had $503,997,302 of assets under management, $470,792,108 of which was managed on a discretionary basis and $33,205,194 of which was managed on a non- discretionary basis. While this brochure generally describes the business of HSWM, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on HSWM’s behalf and is subject to the Firm’s supervision or control. Financial Planning and Consulting Services HSWM offers clients a broad range of financial planning and consulting services, which include any or all of the following functions:
• Business Planning
• Cash Flow Forecasting
• Trust and Estate Planning
• Financial Reporting
• Investment Consulting
• Insurance Planning
• Retirement Planning
• Risk Management
• Charitable Giving
• Distribution Planning
• Tax Planning
• Manager Due Diligence While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, HSWM is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. HSWM does recommend from time to time that clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents or registered representatives of a broker-dealer and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage HSWM or its affiliates to provide additional services for compensation. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by HSWM under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising HSWM’s recommendations and/or services. Wealth Management Services HSWM manages client investment portfolios on a discretionary or non-discretionary basis. In addition, HSWM generally provides clients with wealth management services which include a broad range of comprehensive financial planning and consulting services as well as discretionary and/or non- discretionary management of investment portfolios. HSWM primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), exchange-traded notes (“ETNs”), and individual debt and equity securities and options in accordance with their stated investment objectives. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios. Clients can engage HSWM to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, HSWM directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. HSWM tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on

a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. HSWM consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify HSWM if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if HSWM determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. For certain clients, HSWM allocates (and/or recommends that the client allocate) a portion of client’s investment assets among unaffiliated independent investment managers (“Independent Manager(s)”) in accordance with the client’s designated investment objective(s). The client may be required to enter into a separate agreement with the Independent Manager(s), which will set forth the terms of the client’s engagement with the Independent Manager(s). Clients are encouraged to review the separate account manager’s Form ADV disclosure brochures for separate account manager fees, services offered and conflicts prior to establishing an account with the separate account manager. Independent Manager(s) will have day-to-day responsibility for the active discretionary management of the allocated assets. The firm will continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. The factors the firm considers in recommending Independent Manager(s) include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fee charged by the Independent Manager(s) is separate from, and in addition to, the firm’s advisory fee as set forth in Item 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 HSWM recommends that a client roll over their retirement plan assets into an account to be managed by the Firm, such a recommendation creates a conflict of interest. HSWM will earn new (or increase its current) compensation as a result of the rollover. No client is under any obligation to rollover retirement plan assets into an account managed by HSWM. The Firm's Chief Compliance Officer, Carson Strickland, 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. Retirement Plan Consulting Services HSWM provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and may include any or all of the following services:
• Plan Design and Strategy
• Plan Review and Evaluation
• Executive Planning & Benefits
• Investment Selection
• Plan Fee and Cost Analysis
• Plan Committee Consultation
• Fiduciary and Compliance
• Participant Education As disclosed in the Advisory Agreement, certain of the foregoing services are provided by HSWM as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of HSWM’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. This 408(b)(2) summary is prepared and provided to clients by the plan's recordkeeper and/or third party administrator, subject to review by HSWM.