Description of Services and Fees Hinchley Advisory Group is a registered investment adviser based in Centennial, Colorado. We are organized as a limited liability company under the laws of the State of Colorado. Bruce D. Hinchley is our principal owner. The Firm has been registered since November 2011. We are registered with our home state of Colorado and in such other states where required by law. We only conduct advisory business in those states where we are regsitered or exempt from registration. We are also approved to conduct advisory business in the state of Minnesota as of 08/2023. Currently, we offer Portfolio Management Services which are personalized to each individual client.
The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we", "our" and "us" refer to Hinchley Advisory Group and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person throughout this brochure. As used in this brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm.
We use the terms "we" and "our" throughout this disclosure brochure to refer to the firm as an entity. The use of these terms is not intended to imply that there is more than one individual associated providing investment advice on behalf of this firm. Portfolio Management Services We offer discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. We will use the suitability information we gather to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf. As part of our portfolio management services, we will customize an investment portfolio for you in accordance with your risk tolerance and investing objectives. We may also invest your assets using a predefined strategy, or we may invest your assets according to one or more model portfolios developed by our firm. Once we construct an investment portfolio for you, or select a model portfolio, we will monitor your portfolio's performance on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances.
In conjunction with our Porfolio Management Service, we include financial planning at no additional charge. Financial planning typically involves providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. If you retain our firm, we will meet with you to gather information about your financial circumstances and objectives. We may also use financial planning software to determine your current financial position and to define and quantify your long-term goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm and the data derived from our financial planning software, we will deliver a written plan to you, designed to help you achieve your stated financial goals and objectives.
Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to our firm. You must promptly notify our firm if your financial situation, goals, objectives, or needs change.
4 The following generally describes our model portfolios: Growth - this portfolio seeks to maximize capital appreciation and is not concerned with current income. The portfolio is designed for investors who have a high risk tolerance and are willing to accept greater volatility in exchange for greater potential capital appreciation.
Moderate Growth – this portfolio seeks capital appreciation and is not concerned with current income.
The portfolio is designed for investors who have a high risk tolerance and are willing to accept volatility in exchange for potential capital appreciation.
Balanced – this portfolio seeks to provide moderate capital appreciation and limited current income with a secondary goal of capital preservation. This portfolio is designed for investors who have a moderate risk tolerance and are willing to accept limited volatility in pursuit of moderate capital appreciation.
Moderately Conservative – this portfolio seeks to provide limited capital appreciation and modest current income with a secondary goal of capital preservation. This portfolio is designed for investors who wish to limit their exposure to risk but are willing to accept some portfolio volatility in pursuit of modest capital appreciation.
Conservative - this portfolio seeks to provide preservation of capital, inflation protection, and current income. Capital appreciation is a secondary goal. This portfolio is designed for investors who have a low risk tolerance and are willing to accept commensurate returns in exchange for asset protection.
If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted

by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. In providing discretionary management services, we do not accept client restrictions on the specific securities or the types of securities that may be held in their account. Types of Investments While we primarily recommend mutual funds, variable annuities, and variable life insurance, we may offer advice on any type of investment that a client may have in their portfolio,or inquire about.
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);
•Avoid misleading statements about conflicts of interest, fees, and investments; 5
•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.
Assets Under Management As of January 5, 2024, we provide continuous management services for $124,704,176 in client assets on a discretionary basis.
Conflicts of Interest In general, conflicts of interest arise in situations where we: (1) have the ability to receive a financial gain, or avoid a financial loss, at the expense of the client; (2) have a financial or other incentive to recommend a particular product, service, or provider or to favour the interest of another client or group of clients over the interests of the client; and (3) receive or will receive from a person other than the client an inducement in relation to a service provided to the client, in the form of monies, goods or services, other than the standard commission or fee for that service. As a registered investment adviser, we have a fiduciary duty to you, which means we have an affirmative duty to act in utmost good faith towards you and provide you with full and fair disclosure of all material facts. In order to comply with that duty, all of our associated persons are required to place the interests of our clients ahead of their own when making personal investments. In addition, we require that client transactions be placed before associated persons' personal transactions. Personal trading by associated persons is monitored by our compliance personnel and they are required to submit personal trading reports on a quarterly basis for review.
In addition, we have adopted a Code of Ethics which addresses personal securities reporting procedures. We have also adopted written policies and procedures that address such procedures and that are designed to detect and prevent associated persons from gaining an unfair advantage. To further mitigate conflicts, we: Take all reasonable steps to identify and, where possible, avoid conflicts of interest between us (or any person or entity directly or indirectly linked to the firm by control) and our clients; Put in place appropriate information controls or barriers; Prepare, maintain, and implement a Written Policy that includes regular reports and supervision; Provide our Code of Ethics to clients upon request; Disclose the general nature and sources of conflicts of interests; and Maintain records of the services and activities performed where a conflict has arisen or may arise.
General Information on Advisory Services and Fees For residents of Massachusetts - Pursuant to 950 CMR12.205 (8)(d), the disciplinary history, if any, of all investment advisors and their representatives may be obtained by calling The Massachusetts Securities Division at (617) 727-3548. 6 For Residents of California - Pursuant to California Code of Regulations, 10 CCR Section 260.235.2, Hinchley Advisory Group, LLC hereby makes the following statement: As it relates to Financial Planning Services, a conflict exists between the interest of Hinchley Advisory Group, LLC and the interests of the client. Further, the client is under no obligation to act upon Hinchley Advisory Group, LLC's recommendations, and if the client elects to act on any of the recommendations, the client is under no obligation to effect the transactions through Hinchley Advisory Group, LLC.
All material conflicts of interest under CCR Section 260.238(k) are disclosed regarding the investment adviser, its representatives or any of its employees, which could be reasonably expected to impair the rendering of unbiased and objective advice.
While the firm endeavors at all times to offer clients its specialized services at reasonable costs, the fees charged by other advisers for comparable services may be lower than the fees charged by Hinchley Advisory Group, LLC.