Description of Advisory Firm
HFM Investment Advisors, LLC is registered as an Investment Advisor located in the State of New
Jersey. We were founded on June 12, 2017. Michael P. Pallozzi and Jason F. Gabrieli are the principal
owners of HFM. HFM offers discretionary management activities, provides ongoing continuing
investment supervisory services, financial planning, on-demand financial courses, and Retirement
Plan Services.
Types of Advisory Services
Investment Advisory Services
We offer investment management services by outsourcing asset management, where appropriate, to
third-party money managers (“Subadvisors”) for portfolio management services. We presently use
GeoWealth and Betterment as subadvisor for the majority of our investment management. Some
legacy clients also use Morningstar Investment Services LLC and Brinker Capital, Inc’s subadvisory
services. We assist clients in selecting an appropriate allocation model, completing the Subadvisor’s
investor profile questionnaire, interacting with the Subadvisor and reviewing the Subadvisor.
HFM refers clients to other investment advisors to manage their accounts. This situation creates a
conflict of interest. However, when referring clients to another investment advisor, the client’s best
interest and suitability of the other investment advisors will be the main determining factors of HFM.
This relationship is disclosed to the client at the commencement of the advisory relationship. You are
not obligated, contractually or otherwise, to use the services of any other investment advisors we
recommend. Additionally, HFM will only recommend another investment advisor who is properly
licensed or registered as an investment advisor in the state where the client resides.
Additionally, we are available to meet with the client upon reasonable request to discuss changes in
their personal or financial situation, suitability, and any new or revised restrictions to be applied to
the account. Fees pertaining to this service are outlined in Item 5 of this brochure. This service may
be terminated 14 calendar days written notice.
Held Away Account Management
HFM may also manage clients’ outside or “held away” accounts on a discretionary basis. Such
accounts may include 401(k), 403(b), HSAs, 529s and other accounts that are not held with a custodian
that allows us direct access to and/or the ability to deduct our fees from the account(s). We do this
by leveraging an unaffiliated technology platform or order management system that provides us the
ability to view and make changes to the investments in the account(s) without taking possession of
our clients’ login credentials.
Clients must register with the platform provider and grant HFM access to the account(s). Once our
access is established, we will review the available investment options, select an allocation in
accordance with the client’s stated objectives and financial goals, monitor the account and make
changes on a discretionary basis.
Financial Planning
Financial planning is a comprehensive evaluation of a client’s current and future financial state by
using currently known variables to predict future cash flows, asset values and withdrawal plans. The
key defining aspect of financial planning is that through the financial planning process, all questions,
information and analysis will be considered as they impact and are impacted by the entire financial
and life situation of the client.
The client always has the right to decide whether or not to act upon our recommendations. If the
client elects to act on any of the recommendations, the client always has the right to affect the
transactions through anyone of their choosing. This service may be terminated 14 calendar days
written notice.
In general, the financial plan will address any or all of the following areas of concern. The client and
advisor will work together to select the specific areas to cover. These areas may include, but are not
limited to, the following:
• Business Planning: We provide consulting services for clients who currently operate their own
business, are considering starting a business, or are planning for an exit from their current
business. Under this type of engagement, we work with you to assess your current situation,
identify your objectives, and develop a plan aimed at achieving your goals.
• Cash Flow and Debt Management: We will conduct a review of your income and expenses to
determine your current surplus or deficit along with advice on prioritizing how any surplus
should be used or how to reduce expenses if they exceed your income. Advice may also be
provided on which debts to pay off first based on factors such as the interest rate of the debt
and any income tax ramifications. We may also recommend what we believe to be an
appropriate cash reserve that should be considered for emergencies and other financial goals,
along with a review of accounts (such as money market funds) for such reserves, plus
strategies to save desired amounts.
• College Savings: Includes projecting the amount that will be needed to achieve college or
other post-secondary education funding goals, along with advice on ways for you to save the
desired amount. Recommendations as to savings strategies are included, and, if needed, we
will review your financial picture as it relates to eligibility for financial aid or the best way to
contribute to grandchildren (if appropriate).
• Employee Benefits Optimization: We will provide review and analysis as to whether you, as
an employee, are taking the maximum advantage possible of your employee benefits. If you
are a business owner, we will consider and/or recommend the various benefit programs that
can be structured to meet both business and personal retirement goals.
• Estate Planning: This usually includes an analysis of your exposure to estate taxes and your
current estate plan, which may include whether you have a will, powers of attorney, trusts
and other related documents. Our advice also typically includes ways for you to minimize or
avoid future estate taxes by implementing appropriate estate planning strategies such as the
use of applicable trusts.
We always recommend that you consult with a qualified attorney when you initiate, update,
or complete estate planning activities. We may provide you with contact information for
attorneys who specialize in estate planning when you wish to hire an attorney for such
purposes. From time-to-time, we will participate in meetings or phone calls between you and
your attorney with your approval or request.
• Financial Goals: We will help clients identify financial goals and develop a plan to reach them.
We will identify what you plan to accomplish, what resources you will need to make it happen,
how much time you will need to reach the goal, and how much you should budget for your
goal.
• Insurance: Review of existing policies to ensure proper coverage for life, health, disability,
long-term care, liability, home and automobile.
• Portfolio Analysis: This is a service we offer which will look deeply into the holdings of a client’s
portfolio during analysis.
• Retirement Planning: Our retirement planning services typically include projections of your
likelihood of achieving your financial goals, typically focusing on financial independence as the
primary objective. For situations where projections show less than the desired results, we may
make recommendations, including those that may impact the original projections by adjusting
certain variables (e.g., working longer, saving more, spending less, taking more risk with
investments).
If you are near retirement or already retired, advice may be given on appropriate distribution
strategies to minimize the likelihood of running out of money or having to adversely alter
spending during your retirement years.
• Risk Management: A risk management review includes an analysis of your exposure to major
risks that could have a significantly adverse effect on your financial picture, such as premature
death, disability, property and casualty losses, or the need for long-term care planning. Advice
may be provided on ways to minimize such risks and about weighing the costs of purchasing
insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing
insurance (“self-insuring”).
• Tax Planning Strategies: Advice may include ways to minimize current and future income taxes
as a part of your overall financial planning picture. For example, we may make
recommendations on which type of account(s) or specific investments should be owned based
in part on their “tax efficiency,” with consideration that there is always a possibility of future
changes to federal, state or local tax laws and rates that may affect your situation.
We recommend that you consult with a qualified tax professional before initiating any tax
planning strategy, and we may provide you with contact information for accountants or
attorneys who specialize in this area if you wish to hire someone for such purposes. We will
participate in meetings or phone calls between you and your tax professional with your
approval.
It is incumbent on the client to advise us about financial planning issues, and whether they want to
sit down with us and address financial planning matters. We believe financial planning is important
and there should be an ongoing review. However, if the client does not take advantage of this offer,
then there is no change in our fee schedule.
Annual Ongoing Financial Planning
Clients desiring an ongoing relationship after delivery of financial plan, we offer ongoing planning for
clients in the execution of their financial plan. These clients will also receive updates to their financial
plans (as needed) and ongoing support with execution on their financial plan, via phone
and emails.
This service may be terminated 14 calendar days written notice.
HFM60° Modular Financial Planning Sessions
For clients that would like guidance on a single financial planning topic, we offer modular financial
planning sessions. In these sessions, we provide recommendations regarding the specific topic chosen
by the client from our available options. Relevant documents are gathered, objectives are set, and
this plan is then communicated via a one-time virtual meeting session. Topic choices may include:
Investment/Savings Strategy, Student Loan Optimization, College Funding Strategy, and
Insurance/Estate Plan Analysis. This engagement is limited to the planning session and any financial
planning relationship is terminated at the conclusion of the meeting, once the plan and
recommendations are delivered.
Retirement Plan Services
We offer (1) Discretionary Investment Management Services, (2) Non-Discretionary Investment
Advisory Services and/or (3) Retirement Plan Consulting Services to employer-sponsored retirement
plans and their participants. Depending on the type of the Plan and the specific arrangement with
the Sponsor, we may provide one or more of these services. Prior to being engaged by the Sponsor,
we will provide a copy of this Form ADV Part 2A along with a copy of our Privacy Policy and
Retirement Plan Agreement ("Agreement") that contains the information required under Sec.
408(b)(2) of the Employee Retirement Income Security Act ("ERISA") as applicable.
The Agreement authorizes our Investment Adviser Representatives ("IARs") to deliver one or more
of the following services:
Discretionary Investment Management Services
These services are designed to allow the Plan fiduciary to delegate responsibility for managing,
acquiring and disposing of Plan assets that meet the requirements of the Employee Retirement
Income Security Act of 1974 ("ERISA"). We will perform these investment management services
through our IARs and charge fees as described in this Form ADV and the Agreement. If the Plan
is subject to ERISA, we will perform these services as an “investment manager” as defined
under ERISA Section 3(38) and as a “fiduciary” to the Plan as defined under ERISA Section 3(21).
Specifically, the Sponsor may determine that we perform the following services:
MANAGEMENT OF TRUST FUND:
Advisor will review with Sponsor the investment objectives, risk tolerance and goals of the Plan
and provide to Sponsor an IPS that contains criteria from which Advisor will select, monitor and
replace the Plan's investments. Once approved by Sponsor, Advisor will review the investment
options available to the Plan and will select the Plan's investments in accordance with the
criteria set forth in the IPS. On a periodic basis, Advisor will monitor and evaluate the
investments and replace any investment(s) that no longer meet the IPS criteria.
Non-Discretionary Fiduciary Services
These services are designed to allow the Sponsor to retain full discretionary authority or control
over assets of the Plan. We will solely be making recommendations to the Sponsor. We will
perform these Non-Discretionary investment advisory services through our IARs and charge
fees as described in this Form ADV and the Agreement. If the Plan is covered by ERISA, we will
perform these investment advisory services to the Plan as a "fiduciary" defined under ERISA
Section 3(21). The Sponsor may engage us to perform one or more of the following Non-
Discretionary investment advisory services:
INVESTMENT POLICY STATEMENT ("IPS"):
Advisor will review with Sponsor the investment objectives, risk tolerance and goals of the Plan.
If the Plan does not have an IPS, Advisor will provide recommendations to Sponsor to assist
with establishing an IPS. If the Plan has an existing IPS, Advisor will review it for consistency
with the Plan's objectives. If the IPS does not represent the objectives of the Plan, Advisor will
recommend to Sponsor revisions to align the IPS with the Plan's objectives.
ADVICE REGARDING DESIGNATED INVESTMENT ALTERNATIVES ("DIAs"):
Based on the Plan's IPS or other guidelines established by the Plan, Advisor will review the
investment options available to the Plan and will make recommendations to assist Sponsor with
selecting DIAs to be offered to Plan participants. Once Sponsor selects the DIAs, Advisor will, on
a periodic basis and/or upon reasonable request, provide reports and information to assist
Sponsor with monitoring the DIAs. If a DIA is required to be removed, Advisor will provide
recommendations to assist Sponsor with replacing the DIA.
ADVICE REGARDING QUALIFIED DEFAULT INVESTMENT ALTERNATIVE ("QDIA(s)"):
Based on the Plan's IPS or other guidelines established by the Plan, Advisor will review the
investment options available to the Plan and will make recommendations to assist Sponsor with
selecting or replacing the Plan's QDIA(s).
PARTICIPANT INVESTMENT ADVICE:
Advisor will meet with Plan participants, upon reasonable request, to collect information
necessary to identify the Plan participant's investment objectives, risk tolerance, time horizon,
etc. Advisor will provide written recommendations to assist the Plan participant with creating a
portfolio using the Plan's DIAs or Models, if available. The Plan participant retains sole
discretion over the investment of his/her account.
Retirement Plan Consulting Services
Retirement Plan Consulting Services are designed to allow our IARs to assist the Sponsor in
meeting his/her fiduciary duties to administer the Plan in the best interests of Plan participants
and their beneficiaries. Retirement Plan Consulting Services are performed so that they would
not be considered “investment advice” under ERISA. The Sponsor may elect for our IARs to
assist with any of the following services:
Administrative Support
✓ Assist Sponsor in reviewing objectives and options available through the Plan
✓ Review Plan committee structure and administrative policies/procedures
✓ Recommend Plan participant education and communication policies under ERISA 404(c)
✓ Assist with development/maintenance of fiduciary audit file and document retention policies
✓ Deliver fiduciary training and/or education periodically or upon reasonable request
✓ Recommend procedures for responding to Plan participant requests
Service Provider Support
✓ Assist fiduciaries with a process to select, monitor and replace service providers
✓ Assist fiduciaries with review of Covered Service Providers ("CSP") and fee benchmarking
✓ Provide reports and/or information designed to assist fiduciaries with monitoring CSPs
✓ Assist with use of ERISA Spending Accounts or Plan Expense Recapture Accounts to pay CSPs
✓ Assist with preparation and review of Requests for Proposals and/or Information
✓ Coordinate and assist with CSP replacement and conversion
Investment Monitoring Support
✓ Periodic review of investment policy in the context of Plan objectives
✓ Assist the Plan committee with monitoring investment performance
✓ Assist with monitoring Designated Investment Managers and/or third-party advice providers
✓ Educate Plan committee members, as needed, regarding replacement of DIA(s) and/or
QDIA(s)
Participant Services
✓ Facilitate group enrollment meetings and coordinate investment education
✓ Assist Plan participants with financial wellness education, retirement planning and/or gap
analysis
Potential Additional Retirement Services Provided Outside of the Agreement
In providing Retirement Plan Services, we and our IARs may establish a client relationship with one
or more Plan participants or beneficiaries. Such client relationships develop in various ways,
including, without limitation:
• as a result of a decision by the Plan participant or beneficiary to purchase services from us not
involving the use of Plan assets;
• as part of an individual or family financial plan for which any specific recommendations
concerning the allocation of assets or investment recommendations relating to assets held
outside of the Plan; or
• through a rollover of an Individual Retirement Account ("IRA Rollover").
If we are providing Retirement Plan Services to a plan, IARs may, when requested by a Plan
participant or beneficiary, arrange to provide services to that participant or beneficiary through a
separate agreement. If a Plan participant or beneficiary desires to affect an IRA Rollover from the
Plan to an account advised or managed by us, IAR will have a conflict of interest if his/her fees are
reasonably expected to be higher than those we would otherwise receive in connection with the
Retirement Plan Services. IAR will disclose relevant information about the applicable fees charged by
us prior to opening an IRA account. Any decision to affect the rollover or about what to do with the
rollover assets remain that of the Plan participant or beneficiary alone.
In providing these optional services, we may offer employers and employees information on other
financial and retirement products or services offered by us and our IARs.
Selection of Other Advisers
We may direct clients to third-party investment advisers. Before selecting other advisers for clients,
we will verify that all recommended advisers are properly licensed, notice filed, or exempt in the
states where our firm is recommending the adviser to clients.
Client Tailored Services and Client Imposed Restrictions
We offer the same suite of services to all of our clients. However, specific client financial plans and
their implementation are dependent upon a client’s current situation (income, tax levels, and risk
tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that
matches restrictions, needs, and targets.
Wrap Fee Programs
We do not participate in wrap fee programs.
Assets Under Management
HFM’s has the following assets under management:
Discretionary Amounts: Non-Discretionary Amounts: Date Calculated:
$257,821,123 $3,379,960 December 2023