A. Firm Information
The following provides information about a variety of topics relating to SJHL Financial Services, LLC d/b/a SJHL
Financial Group (hereinafter referred to as "SJHL” or the “Advisor”), its business practices and conflicts of
interest.
SJHL is an SEC registered investment adviser with its principal office and place of business in Kansas. SJHL was
founded in October 2016, and is owned and operated by Kyle Hawk, Keith Janzen, and Chet Buchman. SJHL is
affiliated with Swindoll, Janzen, Hawk & Loyd, LLC through common ownership.
B. Advisory Services Offered
SJHL offers financial planning and investment advisory services to individuals, pension and profit-sharing plans,
trusts, estates, and small businesses (each referred to as a “Client”). Prior to engaging SJHL, each Client is
required to enter into an investment advisory agreement with SJHL that defines the terms, conditions, authority,
and responsibilities of SJHL and the Client.
SJHL hereby acknowledges that it is a "fiduciary" when the firm’s services are subject to the provisions of ERISA
of 1974, as amended. When we provide 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.
Investment Management Services
SJHL provides customized investment advisory solutions for its clients through continuous personal client contact,
interaction, and oversight while providing discretionary investment management, through its sub-advisor
(described further below), Buckingham Strategic Partners, LLC (“BSP”). SJHL works with each Client to identify
their investment goals and objectives as well as risk tolerance and financial situation to create a portfolio
allocation.
SJHL, in connection with the Client, will identify the Client’s investment goals and objectives, and, with BSP, will
identify the broad strategy[ies] to be employed and develop a strategic asset allocation that is targeted to meet
the identified investment objectives, time horizon, financial situation and tolerance for risk for each Client. Each
Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their
respective portfolio, subject to acceptance by SJHL.
At times, SJHL will provide clients with financial planning recommendations as part of its investment management
services. These services range in nature and scope depending upon the Client’s needs. When financial planning
recommendations are provided, these are done so as part of the investment management services at no additional
cost.
SJHL, with BSP, will provide investment management and ongoing oversight of the Client’s account using a
portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the
Client’s investment goals. Initial public offerings (IPOs) and non-traded REITS are not available through SJHL.
Accounts are managed on a discretionary basis. SJHL will be responsible for selecting funds for the account, and
their amounts.
At no time will SJHL accept or maintain physical custody of a client’s funds or securities. The firm does have
constructive custody due to the direct deduction of SJHL’s fees and due to the use of Standing Letters of
Authorization for third-party money movement with the client’s custodian.
Use of Sub-Adviser
SJHL has contracted with Buckingham Strategic Partners, LLC (“BSP”), for services including trade processing,
collection of management fees, record maintenance, report preparation, marketing assistance, and research. SJHL
has also contracted with BSP as its sub-advisor to provide portfolio management to clients’ accounts. SJHL pays
a fee for these BSP services based on management fees paid to SJHL on accounts that use BSP services. These
fees will not be separately charged to advisory clients. The fee paid by SJHL to BSP varies based on the total
amount of client assets administered and/or sub advised by BSP through SJHL, and as BSP acts as subadvisor for
more client funds, the rate it charges to SJHL decreases; therefore, SJHL has a conflict in that it has an incentive
to recommend more clients work with BSP, which is mitigated by the fact that recommendations that clients
work
with BSP are only made when in the best interests of clients and the decision to work with BSP is ultimately the
client’s.
For investment management services, SJHL will request authority from the client to delegate discretion to trade
in the client’s account, and to receive quarterly payments directly from the client's account held by an independent
custodian. Clients may provide written limited authorization to SJHL or its sub-advisor, BSP, to withdraw fees from
the account. Clients will receive custodial statements showing the advisory fees debited from their account(s).
Certain third-party administrators will calculate and debit SJHL’s fee and remit such fee to SJHL.
Retirement Plan Consulting Services
We offer services to both plan sponsors and participants of retirement benefit plans.
Plan Design and Provider Consulting. We may assist with various aspects of the plan design. We evaluate bundled
or unbundled retirement plan service providers, including record keepers, third party administrators, trustees,
custodians, investment companies and legal and accounting professionals.
Investment Services. We offer assistance in creating and establishing a plan’s asset allocation and in evaluating
and monitoring investment options. This may include reviewing appropriate investment options for the plan,
asset classes and investment styles, evaluating and recommending investment managers, types, and selection of
investment options. We may also conduct periodic reviews of the plan’s investments to evaluate performance,
risk characteristics and expenses and recommend changes where appropriate.
Employee Education Services. We provide services to help plan participants choose an appropriate deferral rate
and investment selection by holding enrollment meetings and providing online or printed educational materials to
encourage participation and help employees choose appropriate deferral rates and investment elections. We may
also work directly with plan participants to help them evaluate their retirement savings goals and implement
appropriate contribution amounts and investments available in the plan.
To assist plan sponsors in fulfilling their ERISA fiduciary responsibilities, we may compare a plan’s services,
investments, features, and fees against those of comparable plans in similar-sized organizations, provide
educational resources to help plan sponsors understand and meet their fiduciary obligations and provide detailed
listings and explanations of all fees paid by the plan and participants to service providers and identify appropriate
opportunities for cost savings.
All recommendations of investment options and portfolios are submitted to the client for ultimate approval or
rejection. Therefore, it is always the client’s responsibility to make changes to the plan itself.
In the event a client contracts with SJHL for one-on-one consulting services with plan participants, those services
are consultative in nature and do not involve SJHL implementing recommendations in individual participant
accounts. It is the responsibility of each participant to implement changes in the participant’s individual accounts.
We can also meet with individual participants to discuss their specific investment risk tolerance, investment time
frame and investment selections. Although we do not implement any transactions in a retirement plan or
participant’s account; we can assist participants with adjusting the allocation percentage of their contributions for
investment options available within their plan upon request.
SJHL does not serve as administrator or trustee of the plan nor does SJHL act as custodian for any client account
or have access to client funds or securities (with the exception of some accounts having written authorization
from the client to deduct our fees and in connection with Standing Letters of Authorization on file with clients’
custodian).
For retirement plan consulting services, the retirement plan or the plan participant who elects to implement any
recommendations made by us is solely responsible for implementing all transactions.
C. Termination of Agreements
Although investment management contemplates an ongoing agreement, the length of service is at the client’s
discretion. The Client or SJHL may terminate the agreement at any time by written notice to the other party upon
advance written notice.
D. Wrap Fee Programs
SJHL does not manage or place Client assets into a wrap fee program.
E. Assets Under Management
As of December 31, 2023, SJHL managed $126,101,847 in assets on a discretionary basis.