INTRODUCTION HHM Wealth Advisors, LLC (hereafter "HHM"), is a fee-based investment adviser that offers three types of advisory services: Portfolio Management Services, Financial Planning Services, and Employee Benefit Retirement Plan Services. HHM Wealth Advisors, LLC (HHM), currently an SEC-Registered investment advisor, began its existence on June 2, 1999 as SecureLife Personal Financial Services, LLC, and remained as such until April, 2003 when the entity changed its name to HHM Capital Advisors, LLC. In June of 2006, HHM admitted two new equity Members substantially increasing the firm's assets under management. On July 1, 2006 the name of the firm was changed to Evergreen Management, LLC. On June 30, 2009, one of its major Members decided to leave the firm to pursue his own succession plan and the firm was renamed to HHM Wealth Advisors, LLC.
As of January 1, 2023, HHM has two principal owners (those individuals and/or entities controlling 25% or more of the company): The CPA Group LLC, DBA Henderson Hutcherson and McCullough, PLLC, HHM CPAs owns 62.25% of the entity and Travis Hutchinson maintains 33.75% ownership.
INITIAL CONSULTATION HHM will begin by providing the Client an initial consultation. HHM uses the initial consultation to:
• Introduce the Client to HHM's firm, its services, and staff
• Gather information about the Client's investment objectives, financial condition, and risk tolerance, which HHM uses in forming its investment advice
• Reach an agreement on the terms of service and compensation arrangements. The consultation must be completed before HHM will make any specific recommendations about the client's asset allocation or securities to buy or sell. Clients may restrict their investments to certain securities or types of securities purchased in their portfolio.
At the conclusion of the initial consultation, the client will sign HHM's Investment Advisory Agreement, which serves as the contract between the Client and HHM, specifying the precise nature of services to be rendered by HHM and fees to be paid by the Client.
PORTFOLIO MANAGEMENT SERVICES If the Client elects Portfolio Management Services, the Client will have the choice of whether the portfolio management is performed on a discretionary or non-discretionary basis. HHM primarily seeks to manage Client accounts on a discretionary basis, but can accommodate non-discretionary management services to those Clients that want to be consulted prior to each transaction. Whether discretionary or non-discretionary, HHM will evaluate the Client's financial condition and risk tolerance in order to tailor the Client's securities selection to meet the Client's investment objectives and individual needs. HHM also allows the Client to impose any restrictions on investing in certain securities or types of securities.
HHM will make ongoing recommendations primarily involving: exchange-listed stocks, preferred stocks, mutual funds (no-load or load-waived only), exchange-traded funds (ETFs), stock options, REITs, and bonds. Given that the market will affect the value of these securities, HHM will monitor Client accounts on an ongoing basis so that it may make any necessary transactions in discretionary accounts or make any necessary recommendations to Clients in non-discretionary accounts. The securities mentioned above reflect a broad range of investment risks, including some securities that entail high degrees of risk, such as stock options.
4 HHM does not provide any "wrap programs" (programs that bundle brokerage and advisory services under a single comprehensive fee). Securities recommended by HHM include additional transaction fees or trade commissions charged by the Client's broker-dealer/custodian which are separate from HHM's advisory fees. (Refer to Item 5 – Fees and Compensation) DISCRETIONARY PORTFOLIO MANAGEMENT For discretionary accounts, the Client will grant HHM limited trading authority (discretionary authority) in the Client's brokerage account by executing the appropriate documents with the Client's broker- dealer/custodian. The discretionary authority will allow HHM to enter securities transactions on the Client's behalf, determining which securities and the amount of securities to buy or sell. Clients will be notified of all transactions by trade confirmations from their broker-dealer/custodian.
HHM will also request the Client provide written authorization to allow HHM to automatically deduct its advisory fee from the Client's account (discussed at greater length in Item 5 - Fees And Compensation section of this FIRM BROCHURE).
Most clients will be recommended discretionary portfolio management and therefore, HHM anticipates the vast majority of its Portfolio Management Services will be rendered on a discretionary basis. HHM recommends the Client grant discretionary authority to HHM so that it may execute recommendations in a timely fashion, but Clients should always review their brokerage account statements to verify the trading activity and withdrawals that occur in their account(s). Since our investment strategies and advice are based on each Client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment.
NON-DISCRETIONARY PORTFOLIO MANAGEMENT For non-discretionary accounts, HHM will prepare securities recommendations as it does for discretionary accounts, but will provide these recommendations to the Client directly so that the Client may enter the transaction on their own or direct HHM to do so on the Client's behalf. If you elect to have your accounts managed on a nondiscretionary basis, no changes will be made to the allocation of your account without prior consultation with you and your expressed agreement for each transaction. As of December 31, 2023, we provide continuous management services for $1,028,609,255 in client assets on a discretionary basis, and $39,116,935 in client assets on a non-discretionary basis.
IRA ROLLOVER RECOMMENDATIONS Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. 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. 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); 5
•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. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
IRA ROLLOVER CONSIDERATIONS As part of our consulting and advisory services, we may provide you recommendations and advice concerning your employer retirement plan or other qualified retirement account.
Our recommendations may include that you consider withdrawing the assets from your employer's retirement plan or other qualified retirement account and roll the assets over to an individual retirement account ("IRA"). Further, we offer our management services be applied to those funds and securities rolled into an IRA or other account for which we will receive compensation. If you elect to roll the assets to an IRA that is subject to our management, we will charge

you an asset based fee as described under Item 5-Fees and Compensation. This practice presents a conflict of interest because persons providing investment advice on your behalf have an incentive to recommend a rollover to you for the purpose of generating fee based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by us.
It is important for you to understand many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each.
An employee will typically have four options: 1. Leave the funds in your employer's (former employer's) plan.
2. Move the funds to a new employer's retirement plan.
3. Cash out and take a taxable distribution from the plan.
4. Roll the funds into an IRA rollover account.
Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney.
If you are considering rolling over your retirement funds to an IRA for HHM to manage it is important you understand the following: 1. Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments.
a. Employer retirement plans generally have a more limited investment menu than IRAs.
b. Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds.
2. Your current plan may have lower fees than HHM's fees.
6 a. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA.
b. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs of those products and services.
c. It is likely you will not be charged a management fee and will not receive ongoing asset management services unless you elect to have such services. In the event your plan offers asset management or model management, there may be a fee associated with the services that is more or less than our asset management fee.
3. HHM's strategies may have differing risks than the option(s) provided to you in your plan.
4. Your current plan may offer financial advice, guidance, and/or model management or portfolio options at no additional cost.
5. If you keep your assets titled in a 401k or retirement account, you could potentially delay your required minimum distribution beyond age 73.
6. Your 401k may offer more liability protection than a rollover IRA; each state may vary.
a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors.
7. You may be able to take out a loan on your 401k, but not from an IRA.
8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home.
9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate.
10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name.
It is important that you understand the differences between these types of accounts and to decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this brochure.
FINANCIAL PLANNING SERVICES If the Client elects Financial Planning Services, HHM may extend the initial consultation to include discussions necessary to begin creating a financial plan or may arrange a follow-up meeting to review additional information about the Client's finances. In any case, the Client will have the choice to: (a) Consult with HHM on the Client's overall financial situation and obtain a comprehensive, written financial plan; or (b) Consult with HHM on a specific topic or an individual security. As the Comprehensive Financial Plan option would include the opportunity to discuss many specific topics or any individual security, HHM generally recommends this option for all new Clients. For returning Clients that need to consult with HHM on a specific topic or individual security, they can do so during an Annual Financial Plan Review or engage HHM for a Separate Financial Planning Consultation.
7 COMPREHENSIVE FINANCIAL PLAN HHM will review all aspects of the Client's finances to prepare a written financial plan that makes comprehensive recommendations to help the Client meet their financial objectives. These areas of analysis include: overall asset allocation, securities recommendations, insurance needs, mortgage planning, consumer debt, retirement planning, college planning, trust & estate planning, savings & budgeting, and tax-planning. HHM will compile this financial information and use it to construct a Comprehensive Financial Plan tailored to the Client's specific financial situation. The written financial plan will typically be constructed within a month.
Clients can execute the recommendations within the Comprehensive Financial Plan on their own or HHM can assist in implementation. If Portfolio Management Services are recommended in the Comprehensive Financial Plan, Clients may engage HHM for those Portfolio Management Services as described above.
ANNUAL FINANCIAL PLAN REVIEW As financial conditions or objectives change over time, Clients should engage HHM to review their financial plan annually. Largely, this review is intended to confirm the Client's financial information is accurate, evaluate whether or not the financial plan is reaching its goals and, make any revisions needed due to changes in the Client's personal goals, objectives, or economic circumstances. However, during this annual review, Clients may also raise new objectives or discuss other financial topics of their choice. Also, if Clients experience life-changing events, they may initiate an Annual Financial Plan Review earlier than the typical annual time frame. SEPARATE FINANCIAL PLANNING CONSULTATION If Clients need to consult with HHM outside of the initial consultation(s) that led to their Comprehensive Financial Plan and before their Annual Financial Plan Review, Clients may engage HHM on a limited basis. HHM is available through a Separate Financial Planning Consultation to make changes to a Comprehensive Financial Plan, discuss a specific financial topic, or evaluate a specific securities investment.
EMPLOYEE BENEFIT RETIREMENT PLAN SERVICES HHM also provides retirement plan consulting services and investment selection services to businesses with qualified retirement, profit sharing, pension and 401(k) plans. Retirement Plan assets are custodied at a qualified custodian. HHM maintains relationships with several third party administrators and record keepers for 401(k) plans. These third party administrators and record keepers typically charge their administrative fees directly to the client, separately from HHM.
Generally, the above services are rendered at the retirement plan level. HHM may also enter into a separate client agreement with the plan participant to provide investment advisory and financial planning services.
If such is the case, the normal fees, conditions, and responsibilities stated within this ADV Part 2A and related documents will apply.