The Firm In 2016, the Boston based firm became a state registered investment advisor to offer financial planning services and asset management services. In December 2019, the firm became an SEC registered investment advisor. The firm is also registered with the Qatar Financial Center Regulatory Authority (QFCRA) in Doha, Qatar. Hoopoe Advisors location below is registered as a "Representative Office", which means activity is limited to only soliciting and educating High Net Worth Qatari residents regarding Hoopoe Advisors’ services. The Qatari office is not a branch, and does not keep any client books and records, nor does it provide investment advisory services. Qanat Quartier, The Pearl, Piazza Level, Office G21, Doha, Qatar Mohammad Bilal Kaleem serves as the President and an investment advisor representative of the firm. Suleiman Ali serves as the Chief Compliance Officer and an investment advisor representative of the firm. Hoopoe Advisors provides comprehensive wealth management services for its clients. These services generally include asset management services in connection with a broad range of financial planning services. These services are described in more detail below. Asset Management Through its wrap fee program, Hoopoe Advisors provides discretionary (with permission) and non - discretionary fee based investment advisory services for compensation primarily to individual clients and high-net worth individuals based on the individual goals, objectives, time horizon, and risk tolerance of each client. Please see our separate Wrap Fee Program brochure for information about our advisory asset management services which include, but are not limited to, the following:
• Funds and Investment Management
• Risk Management
• Education Planning
• Estate Planning
• Retirement Planning
• Tax Planning The firm also provides advisory services to a limited number of charities and small businesses, and self-trusteed pension plan clients. Investment adviser representatives provide advice on the purchase and sale of various types of investments, such as mutual funds, exchange-traded funds (“ETFs”), real estate investment trusts (“REITs”), equities, and fixed income securities. 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 them to meet their financial goals. Accounts are reviewed on a regular basis and rebalanced as necessary according to each client’s investment profile. We provide services for non-wrap fee accounts not managed through our recommended custodian, but where we do have discretion. These are primarily qualified retirement accounts, i.e. 401(k) accounts; HSA’s; and other assets we do not custody. We use a third party platform to facilitate management of these held away assets and may leverage an Orde r Management System to implement tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies, considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. Generally, there is no minimum account opening requirement for an advisory account. As of December 2023, the firm has $ 386,446,785 of discretionary assets and $16,005,652 non-discretionary assets under management. Financial Planning Services Hoopoe Advisors, through its investment advisor representatives, may provide personal financial planning tailored to the individual needs of each client for their retirement and/or non -retirement account(s). Such services may be included as part of a comprehensive wealth management engagement or provided separately for a separate fee. Fees for such services are negotiable and detailed in the client agreement. The services take into account information collected from the client such as financial status, investment objectives and tax status, among other data. The amount of time required per plan can vary greatly depending on the scope and complexity of an individual engagement. A particular client’s financial plan will include the relevant types of planning specific to their needs and objectives such as, but not limited to, the following types of planning: 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.
• 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
• Qualified Retirement Plans – evaluate the types of retirement plans established by an employer for the benefit of the company’s employees.
• 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.
• Deferred Compensation Plans – planning for the use of tax deferred funds to be withdrawn and taxed at some point in the future.
• Business Planning – planning for liquidity from the sale of a business; use of buy-sell agreements, key-man insurance and engaging independent legal counsel as needed. The financial plan may include generic recommendations as to general types of investment products or specific securities which may be appropriate for the client to purchase given his/her financial situation and objectives. The client is under no obligation to act upon the investment adviser’s recommendation or purchase such securities. However, if the client desires to purchase securities in order to implement his/her financial plan, IARs of Hoopoe Advisors may make a variety of products available in their capacity as registered representatives of Hoopoe Capital Markets LLC, a registered broker-dealer. This may result in the payment of normal and customary commissions to investment advisor representative of Hoopoe Advisors in their separate capacity as registered representatives of Hoopoe Capital Markets. Depending on the type of account that could be used to implement a financial plan, such compensation may include (but is not limited to) advisory fees, commissions; mark-ups and mark- downs; transaction charges; confirmation charges; small account fees; mutual fund 12b-1 fees; mutual fund sub-transfer agency fees; hedge fund, managed futures, and variable annuity investor servicing fees; retirement plan fees; fees in connection with an insured deposit account program; marketing support payments from mutual fund, annuity and insurance sponsors; administrative servicing fees for trust accounts; referral fees; compensation for directing order flow; and bonuses, awards or other things of value offered by Hoopoe Advisors to the investment advisor representative. To the extent that an investment advisor representative recommends that a client invest in products and/or services that will result in additional compensation being paid, this presents a conflict of interest. Therefore, the investment advisor representative y has a financial incentive to recommend that a financial plan be implemented using a certain product or service over another product or service.
• A conflict exists between the interests of the investment adviser and the interests of the client.
• The client is under no obligation to act upon the investment adviser's recommendation.
• If the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through the investment adviser. Such conflicts are mitigated by an investment advisor representative’s fiduciary duty to act in the best interest of their client. Retirement Plan Advisory Services Hoopoe Advisors offers retirement plan advisory services for all types of retirement accounts (including but not limited to 401(k) plans) on both a discretionary and non-discretionary basis. Retirement Plan Advisory services may include, but are not limited to: o identifying investment objectives and restrictions o providing guidance on various assets classes and investment options o recommending money managers to manage plan assets in ways designed to achieve objectives o monitoring performance of money managers and investment options and making recommendations for changes o recommending other service providers, such as custodians, administrators and broker -dealers o creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Wrap Fee Programs Hoopoe Advisors acts as portfolio manager on a wrap fee program, which is an investment program where the client pays one fee that includes management fees, transaction costs, and certain other administrative fees. Hoopoe Advisors provides portfolio management services solely through its wrap fee program. Hoopoe Advisors receives the advisory fee set forth in its wrap fee brochure as a management fee under the wrap fee program.