Hooker & Holcombe Investment Advisors, Inc. (HHIA) is an SEC-registered investment adviser with its principal place of business located in Bloomfield CT. HHIA began conducting business in 1996 under the name Hooker & Holcombe Investment Solutions. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).
• Hooker & Holcombe, Inc. HHIA offers the following advisory services to our clients: INVESTMENT ADVISORY SERVICES The primary clients for these services are pension, profit sharing plans, 401(k) plans, 403(b) plans, 457(b) plans, and 401(a) plans, but we offer these services, where appropriate, to other post-retirement employee benefit plans (OPEB), trusts, estates and charitable organizations including foundations and endowments. Under this service model HHIA acts as the primary advisor and is responsible for advising the client on virtually all aspects of their investment program. Investment Advisory Services are comprised of nine distinct services but depending on the type of plan or portfolio, not all services will apply to every client. HHIA can provide these services on a discretionary or nondiscretionary basis. Note that throughout this document the word “plan” is used broadly to refer to both retirement plans of all types, and portfolios for trusts, estates, foundations and endowments. Investment Policy Statement Preparation (hereinafter referred to as ''IPS''): We will meet with the client (in person,by telephone, or virtual meeting) to determine an appropriate investment strategy that reflects the plan sponsor's stated investment objectives for management of the overall plan. Our firm then prepares a written IPS detailing plan objectives, investment objectives, investment committee responsibilities, investment guidelines and restrictions, and performance measurement standards. The IPS also lists the criteria for selection or removal of investment vehicles as well as the procedures and timing interval for monitoring of investment performance. Asset Allocation Strategy: For defined benefit pension plans, OPEB plans, foundations, and endowments, HHIA will work with the client to develop an asset allocation strategy which factors in forward looking capital market assumptions, the plan's liability structure, liquidity needs and expected cash inflows and outflows. HHIA, when appropriate, will incorporate modern portfolio theory in evaluating different risk and return scenarios, providing tailored portfolio alternatives to meet a client's specific needs. Selection of Investment Vehicles: The HHIA Investment Committee is responsible for maintaining and monitoring a list of quality investment options (primarily mutual funds and ETFs) across the spectrum of asset classes based on a proprietary quantitative and qualitative rating system. This list of “approved” investment options is the primary (although not exclusive) source for selecting investments for clients’ portfolios. Where investment limitations exist on a custodial platform, or as dictated by client-specific needs, other investment options are considered for inclusion in a client’s portfolio. The number of investments to be recommended will be determined in consultation with the client based on plan specific factors such as size, demographics, and funded status, etc. HHIA regularly reviews client portfolios and the performance of investment managers contained therein in light of the Investment Policy Statement. If HHIA believes that a particular manager is performing inadequately, or if HHIA believes a different ADV Part 2A 5 3/30/2023 manager is more suitable for the client's needs, HHIA will suggest that the client contract with a different one. Under this scenario, HHIA will assist the client in selecting a new manager. Where HHIA acts as a discretionary adviser the same process is followed with the exception that client consent is not required prior to implementation of changes. Monitoring of Investment Performance: HHIA regularly monitors investment performance of client investments and also monitors non- performance factors of investment managers (e.g. portfolio manager changes, investment objective changes, etc.) based on objective evaluation standards. HHIA keeps clients apprised of investment performance with quarterly reports and regular client meetings and proactively works with the client to assure remedial efforts are taken to deal with investments where performance is not meeting established standards. Portfolio Trading and Administration: For defined benefit pension plans, OPEB plans, foundations, and endowments, HHIA will work with the custodian of the assets to set up and remove investment options, effect trades, rebalance the portfolio, and will assist with expense and benefit payments depending on the custodial platform. HHIA acts as a liaison between the client and the custodian to make sure all of the investment related administrative functions of the portfolio are carried out. Asset Allocation Models: Our firm offers asset allocation models within defined contribution plans. This service is typically available only to larger plans. Each allocation model is designed to meet a particular risk based investment goal. Models are composed from the plan's menu of funds that are available to participants to invest in individually. The following is a description of the models. Plans have the option of including selected models, or all of them. Ultra-Conservative Strategy
• The long-term strategic allocation is 0% equities and 100% fixed income
• May be appropriate for those with a very low risk tolerance, or an inability to assume risk, or will begin drawing on their account within the next few years
• Primary objective is preservation of capital
• Primary risks include loss of purchasing power over time due to inflation and reduced likelihood of meeting long-term investment objectives Conservative Strategy
• The long-term strategic allocation is 20% equities and 80% fixed income
• May be appropriate for those with a very low risk tolerance, or an inability to assume risk, or will begin drawing on their account within the next few years
• Primary objectives are high current income and preservation of capital
• Primary risks include loss of purchasing power over time due to inflation and reduced likelihood of meeting long-term investment objectives Moderate Strategy
• The long-term strategic allocation is 40% equities and 60% fixed income ADV Part 2A 6 3/30/2023
• May be appropriate for those with a low risk tolerance and a moderate ability to assume risk, or will begin drawing on their account within the next five years
• Primary objectives are moderate current income and low to moderate capital appreciation
• Primary risks include loss of purchasing power over time due to inflation, loss of principal over the short-term, and reduced likelihood of meeting long-term investment objectives Balanced Strategy
• The long-term strategic allocation is 60% equities and 40% fixed income
• May be appropriate for those with a medium risk tolerance and a moderate ability to assume risk, and do not expect to draw on their account for at least five years
• Primary objectives are current income and moderate capital appreciation
• Primary risks include loss of principal Growth Strategy
• The long-term strategic allocation is 80% equities and 20% fixed income
• May be appropriate for those with a high risk tolerance and a great ability to assume risk and do not expect to draw on their account for at least ten years
• Primary objectives are low current income and high capital appreciation over the long-term
• Primary risks include loss of principal and limited ability to meet cash flow needs with low- risk investments Equity Growth Strategy
• The long-term strategic allocation is 100% equities and 0% fixed income
• May be appropriate for those with a very high risk tolerance and a great ability to assume risk and do not expect to draw on their account for at least fifteen years
• Primary objective is high capital appreciation over the long-term
• Primary risks include loss of principal and inability to meet cash flow needs with low-risk investments We manage these portfolio models on a discretionary basis. We review the models quarterly and tactical adjustments and/or fund changes are made based on market expectations and individual fund performance. Portfolios are automatically rebalanced regularly (typically quarterly) by the plan’s recordkeeper. The models are managed based on the model's goal, rather than on each plan participant's individual needs. Client Communications: We will meet with the client at least annually (in person or virtually) to provide an update on the economic and financial markets. In addition we will conduct a thorough review of the plan's or portfolio's investments and keep the client apprised of the latest regulatory developments that may affect them. We also discuss new investment options or suggest alternatives to existing investments. Clients also receive portfolio review reports quarterly. Employee Communications: For defined contribution plan clients with individual plan participants exercising control over assets in their own account (''self-directed plans''), HHIA offers educational support and investment workshops designed for the plan participants in conjunction with the plan’s other service providers. The nature of the topics to be covered will be determined by us and the client under the guidelines established in ADV Part 2A 7 3/30/2023 ERISA Section 404(c). If deemed appropriate by the plan sponsor, the educational support and investment workshops provide plan participants with individualized investment consultations. Individual Financial Wellness Services: Coinciding with on-site employee education for defined contribution plan clients, HHIA offers an optional comprehensive financial planning review for their employees. It provides one-on-one session during which an HHIA financial counselor discusses goals, risk tolerance, cash flow, budgeting, educational and retirement planning, asset allocation, and estate planning considerations with the employee. INVESTMENT OVERSIGHT SERVICES The primary clients for these services will be pension plans, OPEB plans, profit sharing plans, 401(k) plans, 403(b) plans 457(b) plans, and 401(a) plans but we also offer these services, where appropriate, to trusts, estates and charitable organizations including foundations and endowments. Under this service model HHIA acts in a limited

capacity to oversee the functioning of the plan’s investment program. Typically the plan will also have a primary advisor, or the client will have an investment committee that fulfills the functions of a primary advisor. Investment Oversight Services are comprised of four distinct services but depending on the type of plan, not all services will apply to every client. Investment Policy Statement Review (hereinafter referred to as ''IPS''): Our firm will assist the client in reviewing the plan's written IPS to help ensure that the provisions are adequate and that they are being followed. Monitoring of Investment Performance: HHIA will work with the client to establish objective evaluation standards for investment performance, periodically evaluate and report investment manager performance against established standards and proactively work with the client to ensure remedial efforts are taken to deal with investment performance not meeting established standards. Client Communications: We will meet with the client at least annually (in person or virtually) to provide an update on the economic and financial markets. In addition we will conduct a thorough review of the plan's investments and keep the client apprised of the latest regulatory developments that may affect them. We also discuss new investment options as warranted. Clients also receive portfolio review reports quarterly. Employee Communications: For defined contribution plan clients with individual plan participants exercising control over assets in their own account (''self-directed plans''), HHIA offers educational support and investment workshops designed for the plan participants in conjunction with the plan’s other service providers. The nature of the topics to be covered will be determined by us and the client under the guidelines established in ERISA Section 404(c). If deemed appropriate by the plan sponsor, the educational support and investment workshops provide plan participants with individualized consultations. ADV Part 2A 8 3/30/2023 REQUEST FOR PROPOSAL SERVICE HHIA will assist plan sponsors in their search for an investment adviser and/or investment manager or a custodial/trustee/recordkeeping service provider. HHIA assists the client in soliciting RFP's from qualified service providers, and then reviews, screens, scores, and summarizes the RFP's, and assists with interviews of the vendors. The plan sponsor is responsible for making any final decisions at the conclusion of this process. At the client's request, HHIA will also assist in the transition process to the selected service provider, including interim advisory services during the transition period. INVESTMENT AUDIT SERVICES HHIA assists clients in reviewing the investment practices of their advisers and/or custodial service providers. In performing audits HHIA reviews quality and breadth of investment options, appropriateness of share classes, direct and indirect fees being assessed, and scope and quality of services provided. HHIA provides benchmarks for reasonableness of fees in relation to services provided, considers conflicts of interest of service providers, and looks at contract provisions to ensure they are being adhered to. PUBLICATION OF PERIODICALS HHIA publishes a weekly market review newsletter which includes economic and financial headlines, market performance, interest and currency rates, and commodity prices. No investment recommendations are provided in the newsletter and the information provided does not purport to meet the objectives or needs of any individual or organization. The newsletter is distributed upon request free of charge via email to our advisory clients and is also available for viewing on our website. 403(b)(7) PROGRAM ADVISORY AND EDUCATIONAL SERVICES HHIA provides advisory and educational services to school districts in Connecticut that sponsor a 403(b)(7) mutual fund program. School districts have the option of making this program available to their employees. In general, employees have the option of choosing this program or one of several other programs chosen by the school administrators. The services provided are part of a bundled service arrangement that includes recordkeeping and administrative services provided by Hooker & Holcombe Retirement Services, Inc. (hereinafter, “HHRS”), a corporation related to HHIA through common control and ownership, and custodial services provided by a third party not related to HHIA (the “Custodian”). Services provided by HHIA include: Investment Menu Selection and Monitoring HHIA, on a discretionary basis, selects a menu of mutual funds from the universe of funds that are available on the Custodian’s platform. HHIA generally selects at least two mutual funds from most of the major asset classes, for a total of 40 –50 funds. The selected funds form a standard menu of mutual funds for all school districts participating in the program. HHIA formulates and maintains an Investment Policy Statement (IPS) which applies to all plans serviced by this program. The IPS establishes performance and other quantitative and qualitative criteria for monitoring the funds. HHIA regularly monitors funds and will, on a discretionary basis, add or delete funds from the menu and map investments from discontinued funds into new funds. HHIA does not have any authority or responsibility for, and does not provide any advisory services with respect to the allocation of participants’ contributions and existing account balances among the menu of mutual funds under this program; the participants are solely responsible for determining how to allocate their contributions and account balances. ADV Part 2A 9 3/30/2023 Participant Communication and Education HHIA in conjunction with HHRS will disseminate generic investment information to plan participants in connection with this program via any of the following methods (a) group meetings, (b) individual meetings, (c) written communications, (d) electronic communications, and (e) internet access. All such materials and communications will be solely informational and educational in nature and should not be construed to be investment advice specific to the participant’s unique circumstances. Participants shall be solely responsible for determining how to allocate their contributions and existing account balances among the menu of mutual funds available under the program. CONSULTING SERVICES Institutional clients can also receive investment advice on a more focused basis. This includes advice on only isolated areas of concern such as asset allocation, investment product research, asset / liability modeling, capital market research, etc. Consulting recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. INDIVIDUAL PORTFOLIO MANAGEMENT SERVICES HHIA provides portfolio management services to individuals. Our firm provides continuous advice to the client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop the client's personal investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizon, risk tolerance, liquidity needs, and any other assets that should be taken into consideration when deciding upon an appropriate investment allocation. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. Our investment recommendations are limited to products or services with which we have expertise and will generally include advice regarding the following securities:
• Exchange-listed securities
• Corporate debt securities (other than commercial paper)
• US Treasury securities
• Certificates of deposit
• Municipal securities
• Mutual fund shares
• Separately Managed Accounts
• Stable Value Funds Because some types of investments involve additional degrees of risk, they will only be recommended when consistent with the client's stated investment objectives (e.g. capital preservation, growth and income, capital appreciation), risk tolerance, liquidity needs and time horizon, as well as tax considerations. We manage these advisory accounts on a non-discretionary or discretionary basis. Non-Discretionary Portfolio Management Non-discretionary portfolio management is available to clients with account balances in excess of $1.0 million. HHIA will develop a custom portfolio based on input from the client but implementation and changes will be carried out only after getting approval from the client. HHIA imposes reasonable restrictions on investing in certain securities, types of securities, or industry sectors. ADV Part 2A 10 3/30/2023 Discretionary Portfolio Management Discretionary custom portfolio management is available to clients with account balances in excess of $1.0 million. HHIA will develop a custom portfolio based on input from the client. Following approval from the client HHIA will implement the portfolio. As deemed appropriate, HHIA’s portfolio manager will modify investment options and allocations from time to time based on market conditions, quality of investments, and availability of investment alternatives as part of its portfolio monitoring and maintenance functions. HHIA will inform the client of changes but does not require approval from the client prior to implementation. INDIVIDUAL INVESTMENT OVERSIGHT SERVICES Under this program HHIA provides limited non-discretionary oversight, advice, and monitoring of the client’s investment accounts. The client is responsible for the day to day administration and trading of their accounts and is free to maintain accounts with brokers of their choice. AMOUNT OF MANAGED ASSETS As of 1/1/2023, HHIA had $477.5 million in Assets Under Management which is defined as accounts for which we provide continuous and regular supervisory services. Assets under this definition include all discretionary accounts and only the non-discretionary accounts for which we provide continuous and regular supervisory services including trading and rebalancing authority. Total client assets for which HHIA provides advisory services was $3.595 billion as of 1/1/20232. Assets under this definition include those mentioned above under the definition of regulatory Assets Under Management plus all additional non-discretionary accounts that don’t meet the definition of continuous and regular supervisory services.