A. The Company Horter Investment Management LLC (“HIM”, “we” or “Firm”) is a SEC-registered investment adviser with its principal place of business located in Cincinnati, Ohio. Drew Horter founded the business in 1991 as Horter Asset Management. In 2006 Mr. Horter modified its name with the creation of Horter Investment Management, LLC. Listed below are the Firm's principal shareholders (i.e. those individuals and/or entities controlling 25% or more of this company):
• Drew K Horter, Owner B. Advisory Services The Firm provides continuous and regular investment advice to its clients based on the individual needs of each client. During our data-gathering process, we determine the client’s individual goals and objectives, time horizon, risk tolerance, liquidity needs, net worth, total income and other various suitability factors. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. Based on the information collected, we recommend an investment portfolio appropriate for the client. Horter Investment Advisor Representatives (“IARs” or “advisor”) meet with clients at least annually and, if needed, on a more frequent basis, to review changes to the client’s financial condition, including their goals and objectives, time horizon and risk profile, as well as to review client accounts. We manage these advisory accounts on a discretionary or non-discretionary basis. Investment advice is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. The Firm has formed an Investment Committee which consists of people with investment knowledge and experience. The Committee has overall responsibility for the selection of new investment opportunities as well as evaluating the performance of the current investment portfolio. This includes the ongoing due diligence of approved investments and the initial due diligence of potential new investments. The Committee is also responsible for creating and maintaining Multi Manager Portfolios, or Model Portfolios, which are groupings of two or more third party manager strategies and/or mutual funds. The advisor is ultimately responsible for meeting with clients and recommending investment portfolios that are consistent with their client’s goals and objectives, risk profile, time horizon and other suitability factors. Portfolio Management Programs Based on the information you provide, the advisor may recommend: 1. Multiple investment methodologies or strategies that the Firm creates, and the advisor deems to be consistent with your investment/financial objectives. This is known as a Multi Manager Portfolio or Model Portfolio. 2. A single investment methodology or strategy that the advisor deems to be consistent with your investment/financial objectives. This is known as a Single Manager Portfolio. 3. A customized mix of multiple investment strategies and/or securities that the Advisor deems to be consistent with your investment/financial objectives. This is known as a Custom Portfolio. Multi-manager portfolios offered by the firm include both tactical portfolios and passive portfolios. Tactical portfolios are actively traded models which include allocations to tactical institutional mutual funds and ETF’s, including proprietary tactical mutual funds, as well as to tactical Third-Party Money Managers. All Third-Party Money Managers that we recommend to clients must either be registered as investment advisers with the Securities and Exchange Commission or with the appropriate state authority(ies). We will continuously monitor the performance of any accounts managed by the Third-Party Money Managers and will assume discretionary authority to hire or fire the Third-Party Money Managers where such action is deemed appropriate and in the best interest of the client. Clients should refer to the selected Third-Party Money Manger’s Firm Brochure, if available, or other disclosure document(s) for a full description of the services offered and the investment philosophy employed. Passive portfolios consist primarily of institutional mutual funds and ETF’s that are not actively traded (“Buy and Hold”). Multi Manager Portfolios include allocations to TFA Funds. The TFA Funds may also be available as a single investment strategy or in a Custom Portfolio. The Firm may use its discretion to invest clients directly in TFA Funds, or models with allocations to TFA Funds. The Firm and Drew K. Horter have a financial incentive to recommend TFA Funds to you and to utilize and favor these funds in the Firm’s investment strategies. Clients may elect not to invest in TFA Funds, not to be invested in Models or Custom Portfolios that utilize TFA Funds, and the Client may opt out of an allocation to these funds or models that utilize TFA Funds at any time. Please see additional disclosures related to TFA and certain conflicts of interest, in Items 5, 8, 10 and 11 of this Form ADV. Alternative Investments We may recommend certain investment strategies that provide non-traditional investment opportunities commonly known as alternative investment strategies. Such strategies may include REITs, hedge funds, or private equity or other types of limited partnerships. Nationwide Advisory Solutions Nationwide Advisory Solutions is a No-Load Fee-based RIA Variable Annuity whereby certain Third-Party Money Manager strategies associated with Horter are accessible to Horter clients based on the relevant facts and circumstances of the client. There are no surrender charges, and any policy can be liquidated at any time. The annual contract charges assessed by Nationwide, regardless of the investment amount, are $20/month. Variable Annuity clients pay advisory fees according to the following fee schedule:
• 1.99% Annual Advisory Fee, payable at .4975% per quarter and assessed in arrears based on the average daily balance of assets under management for the previous quarter. Retirement Plan Asset Management Services We offer investment management services to tax-qualified retirement plans, hereafter referred to as “Plan Clients”. Most Plan Clients are defined contribution plans that allow participants to direct the investment of their plan accounts among investment options selected by a responsible fiduciary of the Plan Client (“Responsible Fiduciary”). Other Plan Clients do not offer participant investment direction, in which case the Responsible Fiduciary selects the Plan Client’s investment funds. Plan Clients are generally subject to the provisions of the Employee Retirement Income Security Act of 1974, as amended ("ERISA"). All Plan Client assets are held by Schwab, Axos Advisor Services or Nationwide Advisory Solutions as custodians. Under no circumstances do we hold custody of Plan Client assets. If the Plan Client's responsible fiduciary selects us to offer actively managed investment options, we make available the Third-Party Money Manager programs approved for use in tax-qualified retirement plans. Please note that not all Third-Party Money Managers or strategies utilized by Horter Investment Management are approved for use under this section. In some circumstances, Horter has delegated trading authority to the Third-Party Money Manager. In other circumstances, Horter will place trades according to trading instructions received from the Third-Party Money Manager. Retirement Rollovers Conflicts of Interest: If we provide investment advice to a 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. Under this special rule’s provisions, we must:
• Meet a professional

standard of care when making investment recommendations (give prudent advice).
• Never put our financial interests ahead of yours when making recommendations (give loyal advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that we give advice that is in your best interest.
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). In the event Horter Investment Management recommends that a client roll over their retirement plan assets into an account to be managed by Horter, such a recommendation creates a conflict of interest if Horter will earn an advisory fee on the rolled over assets. When acting in such a capacity, Horter serves as a fiduciary under the Employee Retirement Income Security Act (ERISA). There is a conflict of interest when a Horter Investment Management representative makes a recommendation that a participant roll over assets from a retirement account into a new or existing account or investment (e.g. rollover IRA) managed by Horter.  The conflict of interest exists because Horter will receive compensation (e.g., management fees) if the money is rolled over, but it will not if the recommendation is not accepted. No client is under any obligation to rollover retirement plan assets to an account managed by Horter Investment Management. Horter's Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. The responsible fiduciary may also select various index funds as investment options. Financial Planning Services We provide financial planning services. 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. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients electing this service receive a written report which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for past, current and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability.
• INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio.
• INSURANCE: We review existing policies to ensure proper coverage for life, health, disability and long-term care.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals.
• DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving dependents and estate planning.
• ESTATE: Working with an estate planning attorney, we assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or financial advisor. Implementation of financial plan recommendations is entirely at the client's discretion. Clients who implement the recommendations from their individual advisor should be aware that certain conflicts of interest may exist related to such recommendations. Your advisor may be an insurance producer related to Horter’s insurance agency, Horter Financial Strategies, LLC, or may be related to an unaffiliated insurance agency for which they receive compensation for sales of insurance products; or may be a Registered Representative of a Broker Dealer for which they receive compensation for the sale of securities. It is important to review your advisor’s ADV Part 2B Brochure to determine if any conflicts exist. Typically, the financial plan is presented to the client within three months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Financial Planning recommendations are not limited to any specific product or service offered. All recommendations are of a generic nature. Disclaimers We may provide limited tax and legal information as a consequence of providing investment advisory services to our clients. This information is general in nature, is not complete, and may not apply to your specific situation. It should not be construed as specific legal or tax advice. We make no warranties and are not responsible for your use of this information or for any errors or inaccuracies resulting from your use. Be sure to consult your tax and legal professionals for specific advice related to your situation. As disclosed in Item 10, certain Investment Adviser Representatives of Horter may be affiliated with a tax return solicitation company under common ownership and control with Horter. This entity is involved in the solicitation of tax preparation clients for third party unaffiliated tax preparers, including the provisioning of tax returns to such clients. Clients who participate in tax preparation with Horter’s affiliate are under no obligation to be Clients of Horter. C. Client Tailored Services and Client Imposed Restrictions Horter believes in providing customized investment advice to clients. Advisors may have their own investment and financial planning styles and may make investment recommendations that differ from the multi-manager portfolios offered by the firm (“Custom Portfolios”). Prior to making a recommendation to invest in a Custom Portfolio, the advisor will work with the client to understand their financial needs and risk tolerance. See Item 8 for material risks associated with Custom Portfolios. The client may place reasonable restrictions on their account(s) by providing written instructions to the firm (“Client Instructions”). This includes which individual securities to buy or sell. You may place these restrictions in the form of limitations on a specific security or broad categories of securities. You may also choose to have your accounts managed in a non-discretionary manner (“Non-Managed Account”). D. Wrap Fee Program Horter Investment Management does not participate in wrap fee programs. E. Assets Under Management As of 12/31/2023, Horter was actively managing $211,458,000 of client assets on a discretionary basis plus $2,651,000 client assets on a non-discretionary basis for a total of $214,109,000 in assets under management.