Firm Description Hahn Financial Group, Inc., (“HFG”) was founded in 2006 and became a registered investment advisor in 2014. Kelly Hahn is a 50% owner and Verlyn Hahn is 50% owner. HFG provides investment management to individuals, pension and profit sharing plans, trusts, estates, and charitable organizations. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, insurance review, investment management, education funding, retirement planning, and estate planning. HFG is a fee based investment management firm. The firm also sells insurance products for a commission. HFG does not act as a custodian of client assets. An evaluation of each client's initial situation is assessed via a net worth statement or risk analysis. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Other professionals (e.g., lawyers, accountants, tax preparers, insurance agents, etc.) are engaged directly by the client on an as-needed basis and may charge fees of their own. For example, tax preparation and to the extent your estate plan needs to be updated, the tax preparer and/or attorney will bill the client separately. Conflicts of interest will be disclosed to the client in the event they should occur. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each client are documented in our client files. Investment strategies are created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written client consent. Wrap Fee Programs HFG does not sponsor any wrap fee programs. Types of Advisory Services ASSET MANAGEMENT HFG offers discretionary direct asset management services to advisory clients. HFG will offer clients ongoing portfolio management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The client will authorize HFG discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. Endowments HFG offers discretionary direct asset management services to endowment clients as follows:
• Endowment/Investment Committee Education: Educational presentations for the committee will be informational in nature and intended to provide an overview of the IPS and the Endowment’s investment selections that would align with their IPS.
• Develop Investment Policy Statement (IPS): The Committee’s goals and objectives will be obtained to help determine the appropriate IPS and investment selections.
• Annual Review: Advisor will facilitate an annual review with the Endowment/Investment Committee covering the IPS/Investments to ensure alignment with the Committee’s current goals and objectives.
• Quarterly Reports: quarterly paper statements will be provided to the contact person for the Endowment Committee. SELECTION OF OTHER ADVISORS When deemed appropriate for the client, HFG will select other advisors for the management of some or all of a client’s account. These other advisors may charge fees in addition to the fees charged by HFG or may be paid a portion of the fee charged by HFG. The details on fees will be disclosed in Item 5 of this brochure. Wealth Management, LLC HFG when deemed appropriate for the client will utilize Wealth Management, LLC (“Sub- Advisor”) to perform discretionary investment management services for certain client’s using Sub-Advisor’s Asset Allocation Models. Sub-Advisor shall have discretionary authority for the investment and reinvestment of the designated assets with full authority to buy, sell or otherwise effect investment transactions involving the designated assets in the client’s name and for the client’s account. The authority granted to Sub-Advisor will continue in force until revoked by HFG or client in writing, with such revocation effective upon Sub-Advisor receipt. HFG is the primary investment advisor to the Clients and shall obtain from clients information to determine Client’s financial situation and investment objectives and forward such information to Sub-Advisor in the form reasonably requested by Sub- Advisor prior to Sub-Advisor’s obligation to provide services to client. QUALIFIED PLANS HFG will provide qualified plans with the following services:
• Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Investment options, retention, removal, addition of investment options and all other investment review duties will be assigned to an unaffiliated asset manager.
• Assist the Client in the reviewing and understanding of the investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan, provided by the asset manager. Client shall have the ultimate responsibility to ensure the asset manager continues to follow the IPS and provides the appropriate reports and investment reviews demonstrating that the policies and objectives outlined in the IPS are being followed.
• Educate the Plan Sponsor with respect to the asset manager’s selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants.
• Assist the Plan Sponsor in monitoring investment options by reviewing the periodic asset manager’s investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS, along with the asset manager’s recommendations to maintain, remove or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment recommendations provided by the asset

manager.
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. HFG will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan under this agreement. Any specific recommendations to participants will be under a separate agreement between the participant and HFG.
• Assist in the participant enrollments as needed, in order to increase retirement plan participation among the employees and investment and financial understanding by the employees.
• Meet with the asset manager periodically to understand their policies, procedures, objectives, processing and assist the Plan Sponsor in understanding those policies, procedures, etc. HFG may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between HFG and Client. HFG has no responsibility to provide services related to the following types of assets (“Excluded Assets”): 1. Employer securities; 2. Real estate (except for real estate funds or publicly traded REITs); 3. Stock brokerage accounts or mutual fund windows; 4. Participant loans; 5. Non-publicly traded partnership interests; 6. Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or 7. Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in the calculation of Fees paid to HFG under this Agreement. ERISA PLAN SERVICES HFG provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit sharing plans, cash balance plans, and deferred compensation plans. HFG may act as a 3(21). Limited Scope ERISA 3(21) Fiduciary. HFG may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions on a non-discretionary basis. As an investment advisor HFG has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using HFG can help the plan sponsor mitigate liability by following a diligent process. Fiduciary Services are:
• Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Investment options, retention, removal, addition of investment options and all other investment review duties will be assigned to a 3(38) Fiduciary.
• Assist the Client in the reviewing and understanding of the investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan, provided by the 3(38) Fiduciary. Client shall have the ultimate responsibility to ensure the 3(38) Fiduciary continues to follow the IPS and provides the appropriate reports and investment reviews showing that the policies and objectives outlined in the IPS are being followed.
• Educate the Plan Sponsor with respect to the 3(38) Fiduciary’s selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5.
• Assist the Plan Sponsor in monitoring investment options by reviewing the periodic 3(38) Fiduciary’s investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS, along with the 3(38) Fiduciary’s recommendations to maintain, remove or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment recommendations provided by the 3(38) Fiduciary. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands HFG’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, HFG is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. Advisor will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan under this agreement. Any specific recommendations to participants will be under a separate agreement between the participant and HFG.
• Assist participant enrollments as needed, in order to increase retirement plan participation among the employees and investment and financial understanding by the employees.
• Meet with the 3(38) Fiduciary periodically to understand their policies, procedures, objectives, processing and assist the Plan Sponsor in understanding those policies, procedures, etc. HFG may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Advisor and Client. HFG has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in the calculation of Fees paid to HFG on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. NEWSLETTERS AND PERIODICALS HFG provides newsletters and periodicals to clients. There is no charge to the client for this service. Client Assets under Management HFG has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $122,100,529 $0 May 15, 2024