Firm Hoey Investments, Inc. (“Hoey” or the “Advisor”) is an independently owned SEC- registered advisor. The firm was founded in January 2008 and has one office located in Coatesville, Pennsylvania. It was established by Francis Hoey, who is the majority owner of the firm and serves as President and firm Principal. Hoey Investments provides investment advisory services on a discretionary basis to its clients (individuals, pension and profit-sharing plans, business entities, trusts, estates and charitable organizations, etc.), and, if requested, financial planning and related consulting services. Services INVESTMENT ADVISORY SERVICES: Hoey Investments offers investment management services based on the individual goals, objectives, time horizon and risk tolerance of each client. Advisory services include, but are not limited to:  Investment Strategy/Objective  Asset Allocation  Asset Selection  Regular Portfolio Monitoring The firm primarily allocates client investment assets among various individual equities (stocks), debt (bonds) and fixed income securities, mutual funds and/or exchange traded funds (“ETFs”). FINANCIAL PLANNING AND CONSULTING SERVICES: Hoey Investments may provide financial planning and/or consulting services (e.g., estate planning, insurance planning, etc.) on a stand-alone fee basis. The firm does not serve as an attorney or accountant and therefore does not prepare estate planning documents or tax returns. If requested by the client, Hoey may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional, retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the firm. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. POTENTIAL CONFLICTS OF INTEREST: Limitations of Financial Planning and Non-Investment Consulting Services: As indicated above, to the extent requested by a client, Hoey Investments may provide financial planning and related consulting services. Neither Hoey Investments nor our adviser representatives assist clients with the implementation of any financial plan, unless agreed to do so in writing. Hoey Investments does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with us, if desired. Hoey Investments may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. We do not serve as an attorney or accountant, and no portion of Hoey Investments’ services should be construed as legal or accounting services. Accordingly, Hoey Investments does not prepare estate planning documents or tax returns. To the extent requested by you, Hoey Investments may recommend the services of other professionals for certain non-investment implementation purpose (i.e., attorneys, accountants, insurance agents, etc.), including certain of our representatives in their separate individual capacities as licensed insurance agents. You are under no obligation to engage the services of any such recommended professional. You retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendation from us and/or our representatives. If you engage any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, you agree to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e., attorney, accountant, insurance agent, etc.) shall be responsible for the quality and competency of the services they provide. Retirement Plans: 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). If Hoey Investments recommends that a client roll over their retirement plan assets into an account to be managed by Hoey Investments, such a recommendation creates a conflict of interest if Hoey Investments will earn new (or increase its current) compensation as a result of the rollover. If Hoey Investments provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Hoey Investments is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets to an account managed by Hoey Investments, whether it is from an employer’s plan or an existing IRA. Mutual Funds and Exchange Traded Funds: Hoey Investments may recommend allocating investment assets to mutual funds or exchange traded funds. Most mutual funds and exchange traded funds are available directly to the public. Therefore, a prospective client can obtain many of the funds that may be utilized by Hoey Investments independent of engaging the firm as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Hoey Investment’s initial and ongoing investment advisory services. Portfolio Activity: Hoey Investments has a fiduciary duty to provide services consistent with the client’s best interest. Hoey Investments will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Hoey Investments determines that changes to a client’s portfolio are unnecessary. Clients remain subject to the fees described in Item 5 below during periods of portfolio inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by Hoey Investments will be profitable or equal any specific performance level(s). Cryptocurrency: For clients who want exposure to cryptocurrencies, including Bitcoin, Hoey Investments, may advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, Hoey Investments will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. Hoey Investments does not recommend or advocate the purchase of, or investment in, cryptocurrencies. Hoey Investments considers such an investment to be speculative. Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal. Cash Positions: Hoey Investments continues to treat cash as an asset class. As such, unless Hoey Investments determines to the contrary, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating our advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Hoey Investments may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, our advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts: Certain

account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion Hoey Investments shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless Hoey Investments reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. The above does not apply to the cash component maintained within a Hoey Investments actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager and cash balances maintained for fee billing purposes. The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any Hoey Investments unmanaged accounts. eMoney Advisor Platform: Hoey Investments may provide its clients with access to an online platform hosted by “eMoney Advisor” (“eMoney”). The eMoney platform allows a client to view their complete asset allocation, including those assets that Hoey Investments does not manage (the “Excluded Assets”). Hoey Investments does not provide investment management, monitoring, or implementation services for the Excluded Assets. Unless otherwise specifically agreed to, in writing, Hoey Investments’ service relative to the Excluded Assets is limited to reporting only. Therefore, Hoey Investments shall not be responsible for the investment performance of the Excluded Assets. Rather, the client and/or their advisor(s) that maintain management authority for the Excluded Assets, and not Hoey Investments, shall be exclusively responsible for such investment performance. Without limiting the above, Hoey Investments shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. The client may choose to engage Hoey Investments to manage some or all of the Excluded Assets pursuant to the terms and conditions of an Investment Advisory Agreement between Hoey Investments and the client. The eMoney platform also provides access to other types of information and applications including financial planning concepts and functionality, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by Hoey Investments. Finally, Hoey Investments shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the eMoney platform without Hoey Investments’ assistance or oversight. Client Obligations: In performing our services, Hoey Investments shall not be required to verify any information received from you or from your other professionals and is expressly authorized to rely thereon. Moreover, you are advised that it remains your responsibility to promptly notify Hoey Investments if there is ever any change in your financial situation or investment objectives for the purpose of reviewing, evaluating or revising our previous recommendations and/or services. Cybersecurity Risk: The information technology systems and networks that Hoey Investments and its third-party service providers use to provide services to Hoey Investments’ clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Hoey Investments’ operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Hoey Investments are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although Hoey Investments has established procedures to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that Hoey Investments does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Borrowing Against Assets/Risks: A client who has a need to borrow money could determine to do so by using:
• Margin-The account custodian or broker-dealer lends money to the client. The custodian charges the client interest for the right to borrow money, and uses the assets in the client’s brokerage account as collateral; and,
• Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges investment assets held at the account custodian as collateral. These above-described collateralized loans are generally utilized because they typically provide more favorable interest rates than standard commercial loans. These types of collateralized loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are not without potential material risk to the client’s investment assets. The lender (i.e., custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, Hoey Investments does not recommend such borrowing unless it is for specific short-term purposes (i.e., a bridge loan to purchase a new residence). Hoey Investments does not recommend such borrowing for investment purposes (i.e., to invest borrowed funds in the market). Regardless, if the client was to determine to utilize margin or a pledged assets loan, the following economic benefits would inure to Hoey Investments:
• by taking the loan rather than liquidating assets in the client’s account, Hoey Investments continues to earn a fee on such Account assets; and,
• if the client invests any portion of the loan proceeds in an account to be managed by Hoey Investments, Hoey Investments will receive an advisory fee on the invested amount; and,
• if Hoey Investments’ advisory fee is based upon the higher margined account value, Hoey Investments will earn a correspondingly higher advisory fee. This could provide Hoey Investments with a disincentive to encourage the client to discontinue the use of margin. The Client must accept the above risks and potential corresponding consequences associated with the use of margin or a pledged assets loan. Disclosure Statement: A copy of our written Brochure and Client Relationship Summary, as set forth on Part 2 of Form ADV and Form CRS respectively, shall be provided to you prior to, or contemporaneously with, the execution of our advisory agreement. Client Tailored Services and Client Imposed Restrictions Hoey Investments creates an Investment Objective Statement based on each client’s current situation (income, tax level, time horizon and risk tolerance level). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses and other administrative fees. Hoey Investments does not sponsor or participate in any wrap fee programs. Assets Under Management As of December 31, 2023, Hoey Investments managed approximately $427,460,751 in assets, all of which were discretionary assets.