Introduction
Hadley Investment Co. (“Hadley” or the “Firm”) is a Delaware corporation with its principal
office located in West Hollywood, CA and is registered with the Securities and Exchange
Commission (the “SEC”) as an investment advisor. The Firm was formed in August 2020 and
is solely owned by Joshua Evan Miller. Mr. Miller is the CEO and CCO of the Firm.
Advisory Business
Hadley provides investment advisory services to retail investors exclusively through an
investment services technology platform offered through its website and proprietary mobile
application (the “Platform”). The Firm is an investment advisor that owns and maintains the
Platform through which advisory clients receive investment recommendations to invest in
529 plans which are offered across the 50 U.S. states and several territories. Hadley will only
offer investment recommendations with respect to 529 plans and not individual securities.
The investment recommendations are provided to clients directly by Hadley via the Platform
and clients will directly choose their 529 plan investments.
529 Plans
529 Plans are tax-advantaged savings plans designed to encourage saving for future
education costs. 520 Plans, legally known as “qualified tuition plans”, are sponsored by states,
state agencies or educational institutions and are authorized by Section 529 of the Internal
Revenue Code. Most of the fifty states and the District of Columbia sponsor at least one type
of 529 Plan. The three types of 529 plans are prepaid tuition plans, education saving plans
and 529 ABLE plans. Hadley will focus its initial investment services in education saving
plans.
Client Tailored Services
Hadley utilizes the Platform to collect information with respect to each client and prospective
clients, to deliver account notifications and content, and to provide Hadley’s investment
recommendations. Upon account opening (“Client Onboarding”), the client will be prompted
to complete a series of questions that will be used, in combination with other available client
information collected through the Platform, to deliver 529 plan recommendations. These
series of questions are important to the development of Hadley’s investment
recommendations.
Client Onboarding is complete once a client has (i) electronically accepted and countersigned
Hadley’s investment advisory agreement, (ii) acknowledged receipt of Hadley’s Form ADV
Part 2 (Brochure), Form CRS (Client Relationship Summary) and Privacy Notice. There will
be no exceptions. Only when Client Onboarding is complete will a client have the availability
to receive recommendations and enroll in 529 plan(s) via the Platform.
The Platform
Hadley’s Platform will recommend to its clients a variety of 529 plans which are dependent
on a client’s risk tolerance and asset allocation strategy preference (e.g., static or “age based”
portfolios), and client’s state of residence. Clients initially complete an online questionnaire
and based on those answers a variety of 529 plans are recommended by the Platform. While
the Firm provides recommendations with respect to 529 plans solely through the Platform,
the client makes the ultimate decision regarding the purchase or sale of such 529 plans.
Hadley will recommend the most advantageous 529 plan to a client based on the client’s state
of residence. This information
helps Hadley inform the client, via the Platform, if the client’s
state of residence is a tax neutral state, a tax parity state or if the client qualifies for an in-state
income tax deduction. Hadley recommends that clients contact their tax professional before
making a decision to invest in a 529 plan.
After selecting their state of residence, clients will be prompted by the Platform questionnaire
to choose whether their 529 plan should be 1) age-based or static, and 2) aggressive,
moderate, or conservative in risk.
529 Plan Ratings
Hadley’s algorithm will recommend 529 plans via the Platform based on the interests the
client selects on the initial questionnaire completed by the client during Client Onboarding.
The 529 plan recommendations will be delivered for viewing over the internet via the
Platform. The Platform will show the name of 529 plan(s) that is recommended, the state
issuing the 529 plan, Morningstar rating of gold, silver bronze, neutral, negative, or not
scored, whether there was a rating change, and other available information (such as fees, rate
of return, etc.) for each 529 plan recommendation. Each client is ultimately responsible for
deciding whether to accept and act upon the suggested 529 plan recommendations. Clients
also have the ability to search for 529 plans within the Platform that have not been
recommended and decide whether to purchase those 529 plans.
Hadley will recommend the highest-tier rated 529 plan that is connected to the Hadley
platform. Hadley is expecting to connect client with states that offer either gold-rated plans
or state income tax deductions for in-state 529 plan contributions. Since ratings change
yearly, Hadley expects to introduce a “race to the top” competitive dynamic that incentivizes
states to offer compelling and competitive 529 plan options.
Client Support
Clients should consider that Hadley primarily uses electronic (not telephonic) means to
provide customer support. To receive customer support, clients may contact the Firm using
email or through the Platform. Clients and prospective clients should be comfortable
communicating through those channels. Further, clients should understand that they will
not interact with investment advisory personnel.
Hadley reserves the right to deny any prospective client access to the Platform and to
terminate client accounts for reasons related, but not limited, to unsuitability and/or if clients
fail to timely maintain financial and other information previously provided by the client on
the Platform or update this information on at least an annual basis. A client’s failure to timely
update their information in the Platform could materially impact the quality and applicability
of Hadley’s investment recommendations.
Non‐Discretionary Recommendations
Hadley offers non-discretionary investment recommendations and advisory services to
individual investors. Hadley interacts with investment advisory clients, as well as prospective
clients, solely through the Platform. Hadley does not offer financial planning services, tax,
accounting, or legal advice.
Wrap Fee Programs
Hadley does not currently participate in any wrap fee programs.
Assets Under Management
Hadley does not currently have any assets under management.